Loading...
HomeMy WebLinkAboutUnion 16-04-26IN THE MATTER OF AN ARBITRATION UNDER SECTION 48 OF THE LABOUR RELATIONS ACT 1995 (AS AMENDED) BETWEEN Ontario Public Service Employees Union (“OPSEU” or “the Union”) AND The Ottawa Hospital (the “Hospital” or the “Employer”) And in the matter of a dispute about whether certain individuals employed as “Physician Assistants” [“PAs”] are “paramedical employees” who are covered by the “Paramedical” Collective Agreement [OPSEU Policy Grievance #2008 0464 0010 - dated March 20, 2008] --------------------------------------------------------------------------------------------------------------------- BEFORE R.O. MacDowell (Sole Arbitrator) APPEARANCES For the Union Chris Bryden (Counsel) Michael Donaldson Linda O’Regan Tami McDonald For the Employer J.D. Sharp (Counsel) Maureen Daly Dennis Garvin Mike Hackett Justine Boyd Jennifer Cornick The grievance underlying this proceeding was launched in 2008 under the 2008 Collective Agreement; and the hearing in the matter was eventually, held in Ottawa, Ontario, on the following dates that were fixed in consultation with the parties and their counsel: January 13, 2011, October 25, 2011, April 3 & 4 2012, November 13 & 30 2012, January 28, 2013, October 10, 2013, February 26 & February 27, 2014, March 4 & 6, 2014, November 17 & 18 2014; and April 24, 2015, November 16 & 27 2015. 2 AWARD I - Introduction: what this case is about 1. The Union is the “bargaining agent” for a “bargaining unit” of “paramedical employees” who work at the Ottawa Hospital. The parties are bound by a Collective Agreement, that defines that “paramedical bargaining unit” as follows (emphasis added): Article 1.02 Scope and Recognition -- The parties have agreed upon the following definition of the bargaining unit: All paramedical employees of The Ottawa Hospital/L’Hopital d’Ottawa, save and except supervisors, persons above the rank of supervisor, Laboratory Scientists, Biochemists, Staff of The Ottawa Hospital Research Institute, Occupational Health and Safety Services Personnel, Radiation Safety Personnel, students and students employed during the school vacation period. 2. This “paramedical” bargaining unit covers about 2000 professional and technical employees who work in the roughly 140 job classifications to which (as of 2008) the “Paramedical Collective Agreement” applied. Those classifications were distributed (in 2008) across some 26 different “pay bands” with wage rates varying from about $20 per hour to about $60 per hour. There is great diversity in both pay and work responsibilities, as the following selection of job titles indicates: pharmacist, librarian, vocational counselor, diagnostic imaging technologist, electronics technologist, senior physiotherapist, chiropodist, psychologist, respiratory therapist, dialysis technician, social worker, life skills counsellor, occupational therapist, DI systems administrator, mould room aide, animal care technician, perfusionist (operates a heart-lung machine), sonographer, prosthetist, dental assistant, pathologist assistant. 3. The issue in this case is whether some new employees called “Physician Assistants” (“PAs”) are “paramedical employees” who are within the scope of this “paramedical bargaining unit”. The Union says that they are, and the Hospital says that they are not. 3 4. It is common ground that if the “Physician Assistants” are “paramedical employees” then they are caught by Article 1.02 and their terms and conditions of employment are regulated (inter alia) by the “Paramedical” Collective Agreement. 5. For example, that Collective Agreement requires that the bargaining parties negotiate a salary rate for any new “paramedical” job that is added to the bargaining unit (see Article 26.01); the Agreement influences the paramedical employees’ basic hours of work and benefits (vacation entitlement, sick leave plan, etc.); the Agreement protects the employees’ “job security” in various ways, including giving weight to their “seniority”, regulating “layoffs” and requiring the Hospital to prove “just cause” before discharging someone; there is an independent “grievance-arbitration” process to deal with employee complaints; and so on. 6. Conversely, if the “Physician Assistants” (“PAs”) are not “paramedical employees” then they are “non-union employees” who have to make their own individual arrangements with the Hospital that are embodied in their own individual contracts of employment. 7. It is the difference between being part of an established collective bargaining framework1 on the one hand and a regime of individual employment contracts on the other. 8. With that in mind then, the “interpretation question” in this case can be stated quite simply: are the “Physician Assistants”, “paramedical employees” who fall within the scope of Article 1.02? Or put differently: how “elastic” is the word “paramedical” and, as a matter of interpretation, does it embrace the disputed employees here? 1 In a hospital context that means that the employees’ terms of employment are negotiated between the Union and the Employer; and in the case of disagreement, are determined by a neutral arbitrator. Individual contracts of employment, by contrast, are negotiated by each employee separately, but in the shadow of whatever “policies” the hospital, as a large employer, has developed for its non-union workers. For example in the present case, the PAs appear to be treated for benefits purposes like non -union professionals and certain managers. 4 II – Some mechanics 9. The parties are agreed that I have been properly appointed under the terms of the Collective Agreement and that I have jurisdiction to hear and determine the matters in dispute between them. The parties are also agreed that if I find that the Employer has breached its legal obligations in some way, I have jurisdiction to fashion an appropriate remedy. 10. However, the parties were further agreed that if I conclude that the disputed individuals are “paramedical employees” covered by the “paramedical” Collective Agreement, then, for the time being, I should simply make a declaration to that effect and remain “seized” to deal with any remedial issues that properly flow from the Union’s “policy grievance”. The parties were confident that they could work out such remedial issues between themselves; and of course, if the Union’s position were rejected, then any remedial questions would become moot. 11. The hearing in this matter took place in Ottawa Ontario, on a number of days that were scheduled on the agreement of the parties (between 2011 and the end of 2015); and as it turned out, that hearing consumed all or part of some 17 hearing days. Notice of the proceeding was given to the several PAs who might be affected by this decision; however, none of those individuals chose to participate as a “party” in this proceeding. Nor did they take any personal position on their inclusion, or not, in the “bargaining unit” of “paramedical” employees. 12. On the other hand, one of the PAs - Mike Hackett - was called by the Employer as its main “representative witness” for the PA group as a whole; he was present throughout the hearing; he gave evidence about his background and his work responsibilities; and he assisted the Employer I presenting its case. There is no dispute that the result of this proceeding will apply to all of the PAs, even though I only heard from two of them. 5 III – The nature of the evidence adduced and some general observations on that evidence 13. Most of the background is not in dispute; and over the course of the hearing, I heard quite a bit of evidence about the role of the PAs, their emerging “professional” status and how these newcomers fit into the Hospital’s overall operation. These new employees are not themselves “medical doctors”, but they do have training in the health sciences, and they do “assist” the doctors in many ways, and they do “stand in” for those doctors when they are authorized to do so. They work under the auspices of their doctor’s medical scope of practice and they do the things that they are delegated to do by that doctor. 14. In this respect it was said by the Employer (correctly I find) that the PAs are the “agent” or the “extension” of the individual doctors to whom they are attached. For in fact, the newcomers do precisely what their job title suggests they do: they assist “their” doctor(s) in treating patients in whatever manner the doctor considers appropriate and is permitted by the Hospital’s Medical Directives and Policies - including doing delegated medical or ancillary functions that might otherwise be done by the doctor himself/herself. 15. In the result, the “Physicians’ Assistants” work within the parameters that are set by the physician(s) to whom they are attached; so that they are supervised by, and are immediately answerable to, those physicians. They are also obliged to follow any Hospital Policies or Medical Directives that impinge upon what the PAs are permitted to do or what “their doctor” is permitted to delegate. That is what shapes the daily duties of a PA. 16. However, the Physicians’ Assistants do not work in isolation, nor are patients cared for only by doctors and PAs. The PAs work immediately and most closely with “their own doctors” but like the doctors themselves (and from a treatment perspective), they also work in 6 conjunction with a broad spectrum of other “professional” and “technical” staff who provide patient care or who assist in the diagnosis or treatment process in various ways – including nurses and many different kinds of “paramedical employees” . In this sense the PAs are part of a “health care team” that is led by doctors but that also involves nurses and “paramedical employees” who assist in diagnostics or attend to the patients’ needs in one way or another. 17. There is no dispute that many of these other members of the hospital staff are covered by the “paramedical” Collective Agreement, despite their different professional specialities (like the psychologist, social worker or pharmacist on the one hand, or the dialysis technician, respiratory technologist, physiotherapist or dental assistant on the other). Some of these paramedical employees provide direct hands-on care for patients, while others work in a more auxiliary role. And they are all quite different from one another in terms of their professional background, specialization, status, pay and work responsibilities. 18. Accordingly, for comparison purposes, the Union called a few of those (indisputably) “paramedical employees” as witnesses in order to illustrate the nature and diversity of the “paramedical” bargaining unit – which is to say, the broad practical ambit of the word “paramedical” and thus how those members of the “paramedical” bargaining unit were similar to, or different from, the newcomers and each other. 19. I heard from: Dr. Gretchen Konrad a Staff Psychologist; Tina Alvarez-Wiest an Advanced Practice Physiotherapist and Clincial Practice Coordinator in Physiotherapy; Ruth Thompson, a Chiropodist; Linda O’Regan, a Respiratory Therapist and Union Official; and Paul Aboueid, a Respiratory Technologist who has specialized training in anaesthesia so that he works directly with doctors as an “Anaesthesiology Assistant”. 7 20. In each case, the “paramedical” comparator discussed his/her qualifications, the nature of his/her job, the hospital subdivision in which s/he worked, how s/he went about his/her daily tasks, and how s/he interacted with doctors and patients and other health care professionals. 21. These “paramedical” witnesses also discussed the external regulatory framework that applies to some “paramedical” employees pursuant to the Regulated Health Professions Act (“RHPA”) or related legislation like the Chiropody Act or the Respiratory Therapy Act – that is: their statutorily-prescribed professional responsibilities, and their legally defined “scope of practice”, and the role of the Provincial “Regulatory Colleges” that pertain to their particular specialty (e.g. College of Chiropodists, College of Pharmacists, etc.). Because some of the employees in the paramedical bargaining unit are in statutorily regulated “health professions”, so that there are licensing and competence requirements that they have to maintain, quite apart from anything that the Hospital, as their “employer”, requires of them. 22. However, the PAs are not an independent “health profession” that is recognized like that under the Regulated Health Professions Act. That possibility was considered and rejected in 2012 - primarily because the Health Professions Regulatory Advisory Council (which makes these decisions) did not think that the PAs involved sufficient “risk” to the patients or the public to warrant regulation – noting the high degree of supervision by doctors. Nor is there any profession-specific legislation that applies to PAs, like there is for the Chiropodists or the Registered Respiratory Therapists(“RTs”) and some other “paramedical” groups. 23. On the other hand, there are lots of “paramedical employees” who are outside this regulatory structure too; so the presence or absence of such legal framework is not the sine qua non of “paramedical” status for collective bargaining purposes. Nor, in any case, does this 8 licencing and regulatory regime purport to deal with the employees’ pay, or their terms and conditions of employment, or the description or composition of “bargaining units”, or the content of collective agreements, or any other labour relations or collective bargaining phenomena. 24. These external regulations are about a practitioner’s professional duties and responsibilities in light of the potential risks to the public; they are not about wages or benefits or other economic or employment law issues. Similarly, the Professional Colleges are concerned about practice questions and the public interest, and they do not get involved in collective bargaining matters. And as we will see later on: the PAs do have an evolving professional and educational “framework” even though they are not recognized under the RHPA. 25. The parties also put before me a banker’s box of documentary material (hundreds of pages) pertaining to the expected role of the PAs (because that is something of a “work in progress”) and the existing role of the other “paramedical personnel” with whom they were being compared for “bargaining unit definition purposes” – including, in the latter case, a lot of material that described the paramedical employees’ legally permitted “scope of practice”, their “practice guidelines”, and the education, professional training and professional responsibilities that apply to each paramedical specialty – such as the description of what they can or cannot legally do (again, quite apart from any strictures imposed by the Hospital as their “employer”). 26. This material was not controversial and was admitted without objection. It was voluminous but not contentious. Likewise their job descriptions, which it is agreed are accurate. 27. I also heard from two PAs (Mike Hackett and Gabrielle Papineau), and from Dr. Kravcik, a physician who works with PAs, and from Jen Cornick, a human resources analyst who did a comparison of the PA’s work responsibilities from a pay equity point of view. 9 28. However, I think that I should note, at the outset, that quite a bit of the testimony from the witnesses (including the two PAs who gave evidence) was about their education or qualifications, the kinds of work that they do in the different departments of the Hospital where they are located, and their interactions with patients and with other hospital staff – including with doctors. It was about the health services that the witnesses provided for the patient, who else was involved in that treatment, and who had a decisive “say” or “input” into that particular aspect of patient care – that is, who “called the shots” with respect to some aspect of patient care or patient management (especially the role of the doctors as the notional leaders of the “team”). It was about the range of treatments or interventions that these individuals were permitted to do on their own, or in consultation with others, or with permission, or with different levels of experience and accreditation. And it was about the regulatory structure for their specialty (if there was one) including any ethical or disciplinary features of that external regime. 29. It was not, for the most part, about how these employees were paid in relation to one another, or their varying hours of work, or their vacation or sick leave or overtime entitlements, or their permitted leaves of absence, or the application of their “seniority rights” (if any), or their promotional processes, or the protections for their job security. For example: how layoffs or terminations must be implemented, or their severance pay arrangements, or how their pension or other benefits might be administered, or the framework, including collective agreement grievance procedures, for addressing discipline or performance issues or challenging employer decisions that might be considered “unreasonable” or improper in some way. 30. In other words, it was not about the kinds of employment issues (as opposed to health care delivery issues) that are the focus of collective bargaining and that can lead to provisions in a collective agreement addressing such matters; while, by contrast (to take an 10 example), what a Chiropodist does, or how s/he does it, or how s/he interacts professionally with doctors or other health care professionals, or whose “OK” s/he needs before doing something to a patient’s feet, are not the kinds of things that are likely to surface at the bargaining table or produce some collective agreement provision regulating such work responsibilities. 31. Collective bargaining is mostly “about” employee rights and attaching pay and benefits to an employee’s job duties – something that for non-union employees is done more or less unilaterally by the Employer. It is not normally “about” how specific kinds of work should be done, or who must be consulted first, or (in a hospital setting) how patient needs should be addressed: individually or on the caregiver’s own initiative, or in consultation with other members of the health care team, or pursuant to some prescribed or pre-authorized treatment regimen - especially when that work requires technical proficiency or credentials (although in the end a salary has to be attached to each job and some duties are valued more highly than others). 32. Indeed, in the instant case, the job descriptions that spell out the work responsibilities and expectations for each “paramedical classification” are not even negotiated by the parties, nor (as I understand it) do they form part of the collective agreement.2 They are generated unilaterally by the Hospital; and to the extent that such duties are affected by statutory prescriptions - like someone’s permitted “scope of practice” – they cannot be contradicted by collective bargaining in any event. 33. It is also perfectly plain (all of the witnesses agreed with this) that there is a high degree of collegiality and inter-professional cooperation when doctors and hospital employees 2 These are multi-page documents that set out, in some detail, the job definition, the duties and responsibilities, the required education and knowledge, the degree of initiative and independence of action, the impact of erro rs, internal and external contacts (e.g. with other health care providers, patients or family members), supervision, physical and mental demands and working conditions). 11 are delivering health care to patients – regardless of the professional specialties being deployed, or the composition of the “treatment team”, or the “treatment plan” at that point, or whether someone is unionized, or not, or in one bargaining unit, or another, or working in one of the numerous specialized “silos” that are occupied by paramedical employees. 34. Collective bargaining neither addresses those issues directly nor was there any evidence that “bargaining unit status” gets in the way of employees doing what they need to do for patients (although the Paramedical Collective Agreement does provide that work load issues that impinge upon patient care will be discussed and if there are performance issues, then they may have to be addressed in ways that for unionized employees might engage provisions of the collective agreement which provide procedural and substantive safeguards). 35. However, when the witnesses were asked questions about the “pecking order” and levels of treatment authority in the workplace (such as whether the PA, as the doctor’s alter ego, could direct other employees, like nurses, to do things) those witnesses emphasized that the treatment process was collegial and collaborative. They said that in practical terms, things simply did not unfold that way – and that the doctors were the ones who were ultimately responsible for the treatments that the patients receive or for resolving controversies about patient care. 36. Meeting patient needs was not about giving orders in some paramilitary fashion; but rather about working out, in a collaborative way, what was best for the patient in the circumstances - with the doctor in the lead role, but having regard as well, to the specialized expertise and input of the other caregivers involved. And that is so for the PAs, and for the nurses, and for the paramedical employees who also become involved in patient care from time to time. They work together. 12 37. Furthermore, questions about conflicting decision making authority, friction or professional disagreements were all quite hypothetical. So, for example, Dr. Kravcik opined that a doctor or PA or a nurse could call in a Respiratory Technologist, but that what the RT does when he gets there or how he does it, remains for the RT to determine; yet Dr. Kravcik also said that a PA’s opinion would “carry the day” if it were a “judgement call” and there was no obvious right or wrong answer or any ethical issues in play. He gave no examples; and there is no direct connection with an employee’s placement for bargaining unit purposes. 38. There is no actual evidence about a PA ordering a paramedical employee to do something that the paramedical employee was disinclined to do, or some actual “conflict” that had to be sorted out – although there was general agreement that it was the doctor who was ultimately responsible for treatment choices and for the patient’s well-being, and the PA could convey what the doctor wanted done. So if there were frictions that actually did put someone’s job in jeopardy or engaged managerial or human resources personnel, then I did not hear about them in any concrete way. Not for nurses, and not for paramedical employees either; and in fact, Mr. Hackett confirmed the cooperative and collegial approach that I have described above. 39. Similarly, while it is clear that doctors have a decisive “say” over what paramedical employees do for their (the doctors’) patients and it is the doctor who “invites them into” the treatment process and can decide to disregard their advice or reject their involvement, there is typically a team approach and the players have considerable autonomy within their sphere of expertise. The paramedical employees have to be trusted by the doctor and may face consequences if they do not perform adequately – or if inter-personal friction impairs the functioning of the team. Professionals are expected to get along with one another even if there 13 are professional disagreements - regardless of whether their terms of employment are established by collective bargaining or by individual dealings with their employer. 40. Moreover, interesting as it was to hear about who can do suturing, or put in or remove surgical staples, or do the “closing up” in a routine surgery, or initiate intubation, or cut into some tissues, or treat abscesses, or order up one kind of drug or test or other, or bring in or operate some kind of high-tech machine, or deliver bad news to a patient or his family, it is obvious that these things don’t have much to do with collective bargaining – although mastery of such skills or responsibilities may influence the salary that is paid to an employee, and carrying out those duties may, for unionized employees, engage some collective agreement provision (like paying overtime if someone has to work longer hours). Nor, for reasons that I will discuss later on, do I think that analyzing “work” functions in this very detailed way ultimately helps very much with the interpretation problem that is presented in this case. 41. Be that as it may, the issue before me certainly does have a “collective bargaining” context (it is about a “bargaining unit” after all); and with that in mind, the parties also provided me with some “labour relations history” about where the “paramedical” bargaining unit at Ottawa Hospital originally “comes from” and how it has evolved over the years. 42. This branch of the evidence helps to “situate” the “paramedical” bargaining unit in the mosaic of other collective bargaining relationships that the Hospital has with other unions or associations, representing other kinds of employees, in other kinds of “bargaining units”. 43. For as we will see later on: the “paramedical bargaining unit” is one of the several “generic groupings” of employees who typically bargain together in public hospitals in Ontario; and in this respect the Ottawa Hospital is not unique. It mimics the Ontario pattern. That is why 14 the Union put in some material about where the “paramedical” terminology originated and what that term “paramedical” typically means in labour relations practice and parlance. 44. This evidence was a reminder that the “bargaining unit” is related to “collective bargaining” and that the word “paramedical” is being used in a collective bargaining context, for a collective bargaining purpose, in a Province where there are lots of other hospitals that also have “paramedical” bargaining units. It is a collective bargaining term that is widely used in the community; and it has to be read in that light. It is not about “health care delivery”, as such. 45. The parties also adduced some evidence about why certain employees are specifically excluded from the particular “paramedical” group found at the Ottawa Hospital (see the list of employee types following the “save and except” inflection point in Article 1.02). 46. However, it seems to be common ground that the word “paramedical”, itself, was drawn from the language used by the Ontario Labour Relations Board (“OLRB”) which has historically created and described such “bargaining units” in the hospital sector, as part of its statutory mandate to regulate the “structure” of collective bargaining in Ontario. 47. The OLRB does this under the Ontario Labour Relations Act (“OLRA”) when a union is seeking to represent a group of unrepresented workers or when there are corporate changes that impact upon existing collective bargaining structures. The OLRB also operates under the Public Service Labour Relations Transition Act (“PSLRTA”) whose purpose (inter alia) is to “rationalize” bargaining units when public institutions have been merged or amalgamated or otherwise reorganized in some way. In both cases the OLRB can define or redefine bargaining unit perimeters or settle issues of bargaining unit composition. 15 48. In the result, the adjective “paramedical” is the “label” that the OLRB has attached to one of the several “generic” bargaining units that the OLRB has established for collective bargaining purposes in public hospitals; so it is not a term that is solely of the parties’ own devising. Rather, it is a policy-laden word that originates with the OLRB and that reflects, to some extent, the OLRB’s views about what hospital bargaining unit structure “should look like”. And from that perspective, it may also be a clue to bargaining unit composition. 49. To be clear: I am not the OLRB and the issue before me, as an arbitrator, is not whether some disputed individuals “should be” in the paramedical bargaining unit, but rather whether they actually “are” in it as a matter of interpretation. However I agree with the Union that when answering that interpretation question, it may be helpful to understand the origins and the normal ambit of the labour relations terminology that is the focus of controversy in this case. 50. Because if the OLRB has routinely said that certain kinds of employees are, or are not, “paramedical” or “in” the “paramedical” unit when the Board is constructing or revising such units; and if employers and unions embrace that bargaining unit terminology (or it gets thrust upon them by operation of law); then what the OLRB has had to say may provide some guidance about who should be regarded as a “paramedical” employee. 51. It will be convenient to review the factual background in more detail and then return to the narrow interpretation question that is posed in this case. 52. Does the word “paramedical” in Article 1.02 encompass the new PAs, so that they are “in” the “paramedical” bargaining unit, along with many other health care professionals? Are the PAs “paramedical” employees for the purposes of Article 1.02? 16 53. Or (as the Employer argues) are the PAs something else altogether – something entirely different – a completely different kind of “animal”, so to speak – a “medical” employee and not a “paramedical” employee – with the result that the PAs are outside the scope of the “paramedical” bargaining unit defined in Article 1.02? 54. Or to put the proposition advanced by the Hospital a little differently: does characterizing the PAs work as “medical” versus paramedical “matter” for the bargaining unit definition; does this alleged distinction withstand scrutiny; and does it dictate the placement of the PAs, outside the existing “paramedical” bargaining unit defined in Article 1.02? IV - Some Institutional History 55. In 1999-2000 several Ottawa hospitals were merged in order to create a new corporate entity named "the Ottawa Hospital". Those predecessor hospitals were: the Riverside Hospital; the Ottawa General Hospital; the Ottawa Civic Hospital; and the Salvation Army Grace Hospital. Each of those hospitals had its own collective bargaining history with different trade unions and its own collective agreements; so that the bargaining structure and union representation rights in the newly created organization had to be sorted out, post-amalgamation, by an application to the OLRB under the Public Sector Labor Relations Transitions Act. 56. As a result of that proceeding, the parties agreed to and the OLRB endorsed several large generic bargaining units - including a "paramedical unit" - which is not only a "standard unit" that is commonly found in public hospitals, but was also the kind of bargaining unit that was found in some of the predecessor hospitals that were amalgamated to form the new Ottawa Hospital. The OLRB also made some rulings clarifying whether certain disputed occupations were “in” that paramedical unit or were in one of the other generic units in the newly-formed 17 organization – making it clear, though, that the scope of the “paramedical” bargaining unit was not limited to the jobs that received specific OLRB consideration, but embraced all “paramedical” employees. 57. The OLRB also endorsed a separate nurses’ bargaining unit (another “standard unit” in hospitals) and created a combined “service” and “clerical” unit - merging two “standard hospital units” (see below) into an even larger and more inclusive one, that like the paramedical bargaining unit embraces many different types of jobs, with many different wage/salary rates. 58. However, there were no “PAs” employed by any of the predecessor organizations, so there is little direct enlightenment to be found in an examination of the OLRB’s adjudication process (which was conducted in the “consultation format” permitted under the PSLRTA, so there is no recitation of the facts and very little formal reasoning). 59. The OLRB simply endorsed a “standard” “paramedical bargaining unit” (again see the discussion below) reflecting both the practice in Ontario hospitals and the “kinds” of workers who were actively employed by the predecessor hospitals at that time - along with some exclusions or modifications around the edges that the parties had agreed to, or that seemed sensible from a labour relations perspective. There were no PAs in that mix, nor did the OLRB say anything about “medical residents” (who are qualified doctors in a university program that also involves getting advanced training, by working as employees of the hospital who treat patients under the supervision of doctors in the specialties to which the residents aspire). 60. Subsequent collective bargaining was based upon these (mostly) broad employee configurations which, with some minor adjustments, remain to this day. 18 61. Over the years, the parties have occasionally had to grapple with whether particular individuals or occupations were, or were not, “in” that “paramedical” bargaining unit; and, in fact, they have been quite successful in resolving that kind of problem. However I do not think that these agreements (set out in some detail in a Partial Agreed Statement of Fact – Exhibit 17) are very helpful in the instant case, because none of them involved PAs or employees like PAs (leaving aside whether they were without prejudice settlements). Nor were there any evident or agreed upon principles that can be borrowed and applied to the present problem. 62. For example, I am told that the laboratory scientists (who were excluded many years ago pursuant to an earlier OLRB certificate) have remained excluded from the bargaining unit for historical reasons and despite some later discussions with the Union about their status. These individuals run the laboratories, determine policy and procedure and clinical objectives, and are often in positions occupied by physicians (MDs), or PhD biochemists and microbiologists who are not involved in patient treatment. Likewise the research staff, who (I am told) are generally physicians who have their own work groups. The radiation personnel seem to have been excluded because the functions that they perform can result in the shutdown of departments in which bargaining unit-employees work. And so on. 63. None of these situations (or any of the others noted in Exhibit 17) involved PAs or anyone like the PAs; and I do not think that one can distill any principles from these resolutions that are helpful in the instant case. 64. On the other hand, the treatment of “infection control personnel” provides an interesting example of the danger of putting too much emphasis on "work funct ions" when determining the composition bargaining units; because it shows that, in practice, a bargaining 19 unit (which is just a grouping of employees who bargain together under the Labour Relations Act to set their terms of employment) need not be a watertight compartment in terms of the work performed by its members. Because in fact, employees in different bargaining units may actually do the same kind of work; and the “work” of particular jobs can overlap with that of other jobs, regardless of their placement in one bargaining unit or another. 65. For example, I am told that "infection control" functions at the hospital can be performed by either a Registered Nurse, in the Nurses’ bargaining unit (represented by the Ontario Nurses Association) or by a “paramedical” employee, in the “paramedical” bargaining unit (represented by OPSEU). Both bargaining units contain scientifically trained personnel who can do the necessary work; so that when there is an infection control “job vacancy” that has to be filled, that vacancy is “posted” under the job posting provisions in both collective agreements. 66. If the successful applicant is a Registered Nurse then s/he and ‘the job’ will go into the ONA Nurses’ bargaining unit; and if the successful applicant is a “paramedical employee”, then s/he and ‘the job’ will be part of OPSEU’s “paramedical” bargaining unit. It is also clear, from the evidence that a doctor’s duties and a nurse’s duties can overlap too; and that in the absence of legal prescriptions or limitations on “who can do what”, a doctor may decide to delegate things to others or do them himself. 67. In 2002 there was another restructuring exercise that was triggered by the transfer to the Ottawa Hospital of the rehabilitation center that was formerly operated by the Royal Ottawa Health Group; and a further reorganization took place in 2005, when Cancer Care Ontario divested a number of operations that were "picked up" by local hospitals. Once again there was a sorting out of positions into the standard units in place at the Ottawa Hospital; and, 20 once again, there was no emergent principle that is helpful for the present case. 3 There is little enlightenment to be gained from an exercise that did not involve PAs. 68. By and large, there have been no fundamental changes in the scope of the “paramedical” bargaining unit over the years; and issues with respect to the inclusion of new occupational groups have been worked out between the parties pragmatically and without significant controversy. Likewise when issues have arisen as to whether someone was or was not a "managerial" employee [an issue which engages section 1 (3)(b) of the OLRA and can go to the OLRB for a final and binding determination pursuant to section 117 of the Act].4 69. These reorganizations involved defining or redefining bargaining units and putting jobs or employees into those bargaining units for collective bargaining purposes. However, as I have already noted, it is the Employer that "creates” those jobs in the first place, and that generates the job descriptions that, I am told, are not a formal part of the Collective Agreement. 70. On the other hand, Article 26.01 of the Paramedical Collective Agreement does require the Union and the Employer to work out the salary rate for any newly-created paramedical job (failing which the matter can be determined by arbitration); and of course, legislation may affect what particular employees are or are not permitted to do, and what education or accreditation or licensing may be required to occupy the job in question, or perform particular duties. Such education, expertise, accreditation or professional responsibilities may also influence an emplo yee’s salary level, however it is determined. 3 For example, in one instance, in the course of these various reorganizations, OPSEU abandoned a quite plausible claim that certain persons were "in" the “paramedical” unit (and not the combined office/service unit as CUPE claimed) in order to avoid a possible representation vote - which makes practical sense but hardly helps establish a principled basis for inclusion or exclusion. 4 Persons exercising managerial functions are not “employees” under the OLRA and one says that PAs are “managerial” in this sense. See section 1(3)(b) of the OLRA, discussed below. 21 71. But of course, access to the salary-setting mechanism under Article 26.01 depends, in the first instance, upon the new employee being a member the “paramedical” bargaining unit; so that Article 1.02 defines not only the entrance-way into that salary-setting process, but also to the whole array of other rights and obligations that are collectively bargained (or determined by arbitration) and that are set out in the Collective Agreement. 72. Conversely, a contract employee who is excluded from the bargaining unit only has the rights that are in his contract, or that exist at common law, or that are available pursuant to some employment-related statute. 73. The current collective bargaining structure at the Ottawa Hospital reflects this historical evolution and now consists of five distinct employee groupings who engage in a process of collective bargaining as a means of influencing their terms of employment: (1) a paramedical bargaining unit that is represented by OPSEU (approximately 2000 employees); (2) a large amalgamated "service + clerical" bargaining unit, represented by CUPE (approximately 3800 employees); (3) a nurses’ bargaining unit represented by the Ontario Nurses Assoction (“ONA) (3700-3800 employees) (4) a very small bargaining unit of 10 "medical physicists" represented by the Professional Institute of the Public Service of Canada (“PIPS”) and (5) a large grouping of "medical residents" (who bargain together and are represented for that purpose by the Professional Association of Residents of Ontario (PARO) (approximately 1267 Residents) I have used the word “group” in item (5) because it is not clear that residents (being qualified doctors delivering health care) are “employees” in a “bargaining unit” under the OLRA, or that their bargaining process is regulated by the OLRA. 22 V- What PAs do: the evidence of Mike Hackett and Gabrielle Papineau 74. PAs are healthcare professionals who work with physicians to provide healthcare for patients under the supervision of doctors. In that capacity, the PAs take histories, do physical examinations, order and interpret tests, diagnose and treat patients, and counsel those patients in respect of their health issues – speaking on behalf of the doctors for whom the PAs work. 75. I was told that the PAs have been recognized and used in the United States for many years; but in Canada, and until recently, they have only been seen in the Armed Forces - which had limited access to doctors in many environments, so it used PAs as auxiliary health care providers. However about ten years ago, PAs were introduced in Ontario on an experimental basis as part of a pilot project overseen by the Ministry of Health, the Ontario Medical Association, and the Ontario Hospital Association; and as a result of that successful project, PAs are now being widely used in teaching hospitals like the Ottawa Hospital. There are also post- secondary education programs that are designed to train PAs – just as there are programs to train “paramedical” employees. So there is a new and definable group of caregivers on the scene. 76. Whether under the auspices of the military or in a civilian setting, the PAs learning program parallels that of a medical student, with a heavy emphasis on biological sciences, like anatomy, biology, physiology, pharmacology etc. The purpose of that training is to equip the PA to do diagnosis and treatment within the scope of practice of the doctor to whom s/he will later be attached. The education program has been designed to be quite general, so that the PA can later mimic the role of the physician in whatever treatment area that physician practices. 77. The PA works as the “agent” and associate of the doctor – responding to patient needs in a proactive way in whatever manner reduces the doctor’s work load and allows the 23 doctor to deal with more, or more seriously-ill, patients. For example, in addition to doing hands- on patient care, a PA may represent the doctors at meetings, or convey a diagnosis in the same way that the doctor might do (something which cannot be done by a paramedical employee). The PA attends interdisciplinary rounds for educational purposes and to keep in the loop and s/he stands in the shoes of the doctor when delegated to do so – including for controlled medical acts. 78. The PAs “scope of practice” is always linked to that of the doctor to whom s/he is attached, and in this respect, it is unlike that of a paramedical employee whose scope of practice tends to be narrower and fixed and can be rooted in a statute. That means that the PA will typically have a broader level of patient responsibility than a paramedical employee would have – a level of responsibility that is more like that of a medical resident. 79. These propositions were set out in the documentary material that was filed in the course of this proceeding (especially the Canadian Association of Physician Assistants Scope of Practice and National Competence Profile); they were echoed by Dr. Kravcik (who works with PAs); and they were supported by the evidence of PAs Gabrielle Papineau and Mike Hackett – although Mr. Hackett came to the hospital after many years of military experience, while Ms. Papineau joined the hospital staff more recently, after post-secondary training to become a PA. 80. Mr. Hackett said that he spent 25 years in the Armed Forces as a "paramedic" (his choice of words), rising through the ranks and levels of competence. He did extensive training at the Armed Forces Medical School, including many courses and rotations and clerkships, and that he developed a wide range of skills that were confirmed by his teachers and by formal examination. That is what enabled Mr. Hackett to do clinical assessments and treatment plans and become the primary caregiver (in practical terms) for Armed Forces personnel – working 24 with military physiciansm just as he now does with hospital doctors. Mr. Hackett said that he became a generalist, like a medical student, but with without ever getting an “MD”. He did not “prescribe” in his military role, but he did make effective recommendations. 81. Mr. Hackett testified that as a hospital PA, he was effectively “apprenticed” to a doctor (or doctors), and in that capacity, he was able to diagnose and treat the doctors’ patients – not as an independent practitioner, but rather under the direction and supervision of those doctors. Mr. Hackett explained that the initial relationship between the doctor and the PA is tentative and exploratory, however with growing confidence (both his own and that of the doctor) the PA begins to do more of what a doctor does. 82. Mr. Hackett was comfortable with the label “physician extender” which appears in some of the documents that were filed. That term describes someone who amplifies the physician’s work capacity by taking some of the work load off the shoulders of the doctor, which allows the doctor to see more patients (for example, the PA can be permitted to do IVs, or minor surgeries, or sutures or conveying information in the doctor's stead). The PA can also do things that a paramedical employee might do. For example, Mr. Hackett said that he had learned how to do techniques like intubation (something that a Respiratory Therapist n ormally does) and he could perform the procedure (i.e. he had the skill) if he is called upon to do so. 83. Mr. Hackett said that the only limit on what he does as PA is the scope of the doctor's practice, his own competence, his comfort level, and the trust level of the doctor with whom he is working. 84. Mr. Hackett is widely and impressively competent. But his role ultimately, and always, depends upon what the doctor is disposed to delegate. 25 85. Mr. Hackett had a military background. Newly minted PAs, by contrast, come to the job with more limited experience. There is an undergraduate degree program (accredited by the Canadian Medical Association) that is similar to that of medical students, followed by clinical rotations or clerkships, then comprehensive and didactic examinations to test the depth of their knowledge and diagnostic skills. They do not get an M.D. as the medical residents do , and they never become full-fledged doctors; but their education is like that of a medical student. 86. All PAs are expected to meet the requirements set out in the “National Competency Profile and Scope of Practice” document that has been developed by the College of Physicians and Surgeons and the Canadian Association of Physician Assistants (CAPA). However, the PA remains a “generalist” until s/he becomes “apprenticed” to a doctor (as the medical residents do as well), after which the PAs role increasingly merges with that of the doctor. 87. Mr. Hackett testified that while his hospital job description reflected the general CAPA Profile, it was not entirel y accurate because it was not tailored to the specific PA job that he ended up doing with “his” doctors. For example, Mr. Hackett said that he doesn't do basic hematology or electro-cardiology or audiology examinations (which paramedical employees, doctors or residents can also do), while by contrast, he or an RT could do oxygen therapy or maintain airways. And he said that lots of people collect blood. 88. But nothing turns on this detail. Given Mr. Hackett’s level of experience, it is highly likely that he could do anything mentioned in his job description if the occasion arose. For example, he could do a lumbar puncture with the doctor’s authorization; and there is lots of overlap with particular tests that are done by paramedical personnel. I am satisfied that the CAPA profile (Exhibit 1) provides an accurate description of the role and work of a PA. 26 89. Why would someone become a PA? I was told that those who choose the PA role typically do not want to undertake the additional schooling necessary to become a d octor and that they prefer the less demanding lifestyle. There are better hours and a better work/life balance; and in Mr. Hackett’s case, he made that choice after a long career in the Armed Forces. 90. Mr. Hackett said that he now worked with three different doctors on three different internal medicine teams, dealing with as many as 25 patients, who are also cared for by consulting doctors, staff doctors, medical residents, and medical students - and by nurses and paramedical employees. When he comes in to work in the morning he begins by reviewing the patient's overnight experience, and if necessary, he adjusts medications (like diuretics or blood thinners) or other drugs - although he may be circumscribed in that regard by hospital rules with regard to particular medications (like narcotics). He said that the night nurse would need a doctor’s authorization to make such changes, but that he can do it by delegation, working within the parameters of the treatment plan documents. 91. Mr. Hackett also works under Medical Directives that allow him to do controlled acts, tests, and investigations on his own or with more simplified sign-offs. These documents amount to "standing orders" that are approved by the Medicine Department and that are signed off in advance by the participating doctors. They supplement and simplify whatever specific directions or delegations the doctors are comfortable giving to the PAs. 92. The Medical Directives remove the need for some of the prior written formalities that might otherwise be required to do controlled acts, and they facilitate ex post facto confirmation of what has been done by the PA. But the doctor is responsible for ensuring the 27 competence of the PA. There is no Regulatory College applicable to PAs and no legally fixed scope of practice. 5 Mr. Hackett described it as a process of continuous learning by doing. 93. However (as Mr. Hackett put it) the “chain of command” is always through the doctor, who is responsible for the PAs overall supervision and any related critiques. Mr. Hackett said that he was like a medical student who never becomes a doctor. 6 94. Mr. Hackett said that the Medical Directives that apply to him are broader than they once were and that they permit more room for critical judgment than the standing orders applicable to nurses. Registered nurses and emergency nurses can start IVs, order up lab work or x-rays, or hook up monitors; and in that respect, there is an overlap between what PAs do and that nurses do and that other paramedical employees do. And what doctors could do as well. 95. The PA's review the progress of patients in the same manner as medical students and medical residents, liaising and interacting with the doctors or the residents as required. Hence the early morning review of the patients’ situation with whatever adjustments to medications or treatments the PA thinks are necessary; while later on in the day, new patients may be added to the complement - which requires a similar analysis of their history and medications in order to see what has to be done and who else they may be requ ired to see. The orders or changes that PAs make are implemented by nurses or paramedical employees. 96. The PA arranges transfers to other services and in the case of discharge from the hospital, s/he can participate in discharge planning (on behalf of the doctor), meeting with family members, or occupational or physical therapists who have a continuing role in the patient’s 5 It was once thought that the PAs would have formal registration and regulation under the auspices of the College of Physicians and Surgeons, but that did not happen. 6 Medical students working at the hospital also have Medical Directives and are not in any bargaining unit. 28 health. Mr. Hackett said that this is a collective process, but ultimately the PA writes the discharge order on behalf of his supervising physician (since the PA is delegated to do that). At the end of his work day, the PA updates the patients’ situation so that it will be available for the doctors on call, and for the night staff who have to know what needs to be done on their watch. 97. The treatment plan for a new patient is team effort, but there is a considerable degree of latitude for independent PA action within the scope of the plan and in response to the emerging needs of the patient – like ordering diuretics, increasing oxygen levels, adjusting medications, and what might be described as in a nonmedical setting as “troubleshooting”: diagnosing the problem and finding a solution. The PA not only ensures that what has been directed to be done has been done, but s/he can also order new tests or make adjustments to the plan initially put in place by the medical team. 98. According to Mr. Hackett, it is the consult team that puts the treatment plan together in the first place and he adjusts from there – under the supervision of the doctors. It is a collaborative effort and if a co-signature is needed Mr. Hackett said that he could get it by telephone, or later from the doctor; and, as noted, he would routinely initiate medication changes in accordance with a Medical Directive or by writing his own name, then putting "per Dr. X", to indicate the delegation. The PA is responsible for what he himself does, but he is not alone. There is ongoing consultation and review by residents and doctors. It is a team effort. 99. Mr. Hackett also indicated that he consults with nurses and with paramedical employees – like the Pharmacists about drugs; but he was uncomfortable with the suggestion that he was "ordering" them to do things. He noted, for example, that the Pharmacist is the pharmacological specialist and thus the “expert” on the therapeutic use and range of drugs; so 29 that the Pharmacist may suggest a change in medication in response to observations or test results. But the Pharmacist cannot actively change the dose, so (Mr. Hackett said) he and the Pharmacists co-sign the order which is then implemented by nurses. 100. The PA can also write the resuscitation protocol in consultation with the patient and his family, which is then co-signed by the doctor. The PA conveys medical information and diagnoses (like a diagnosis of terminal illness) to the patient's family – which is something that cannot be done by paramedical; and while Mr. Hackett can pronounce the fact of death (there is no evidence that a paramedical employee can do this) he cannot sign the death certificate. The doctor has to do that. The doctor also has to assign code status. 101. Mr. Hackett said that nurses and paramedical employees bring issues to his attention and that he responds to their enquiries and suggestions as a doctor would do if he were available. He is the “go to” person for that purpose. He prefers to discuss such issues with the doctor, but in the meantime he takes whatever action he thinks is necessary. 102. Mr. Hackett emphasized, once again, that treatment is a collaborative process, so that if a Respiratory Therapist (and “RT”) suggests something to him, Mr. Hackett may agree and proceed, or they may discuss it together, and if there is no agreement, then doctor will be told about it. There is a professional dialogue with paramedical employe es who, like the Pharmacists, have specialized expertise of their own. 103. Mr. Hackett confirmed that disagreements with other paramedical professionals or nurses are sorted out by the doctor, but the outcome is signed off by himself or the doctor. The ultimate responsibility for the orders that he makes, falls on the supervising doctor, so the PA must always keep that doctor abreast of what is happening with the patient. 30 104. Mr. Hackett testified that apart from the orders that he writes pursuant to Medical Directives (which a paramedical employee might not be “required to follow” if there were some professional disagreement about it) Mr. Hackett can initiate consultations with paramedical personnel as to the most appropriate technique or treatment response (by a R T for example); and once again, if there is any controversy or uncertainty the PA would bring in the doctor. Mr. Hackett said that he cannot “force” someone to do a test or procedure; but the recipients of such directions are expected to follow them unless there are professional or ethical disagreements, in which case the doctor comes into the picture. 105. However it is important to note that this evidence was all rather conjectural. Mr. Hackett emphasised that professional disagreements of this kind do not generally happen because the treatment process is collaborative and healthcare providers share a common interest in doing what is best for the patient. Other personnel can also be plugged in as needed. For example, if a patient has cognitive issues, a Psychologist might be added to the group. 106. Mr. Hackett said that a PA is not and never can be a doctor or an independent practitioner like some of the paramedical employee can; and it is evident that paramedical employees also (notionally) “get their work” from doctors, who must be satisfied with what is being done. Doctors also work directly with paramedical employees in various capacities (like an anaesthesiologist who works in the operating room with an Anesthesiology Assistant). 107. However, Mr. Hackett thought that his own PA scope of practice was broader and more variable than that of, for example, a nurse practitioner whose role is statutorily defined. He thought that the paramedical employees were more focused and limited, and in my view the evidence supports this viewpoint. 31 108. Mr. Hackett thought that unlike the paramedical personnel working in silos he has a more direct role in diagnosis and treatment and ordering diagnostic tests (like the doctor does) - and also in fashioning a treatment response that can span various silo specialties. For example, if someone like an RT notices a clinical problem (like oxygen saturation), the RT calls on the PA not the doctor. The PA does a patient assessment to see if he can determine what the problem is and what to do about it (for example if there is congestive heart failure or he needs to order diagnostics or medication), then he explains to the doctor what has happened and what he has done. And if puzzled he calls the doctor into the initial decision making process. 109. Mr. Hackett agreed that the PA has a “kind of silo” too, because doct ors they wor for have specialties; but as Mr. Hackett sees it, the PA treats the whole patient, using a broader range of techniques and interventions than individual paramedical employees do. And for the same reason, the PAs role necessarily varies from day to day, and doctor to doctor, and department to department. He said that it is challenging role that involves continuous learning. 110. The doctor sorts out the distribution of patients as between the available PAs - a process that Mr. Hackett said involves a lot of give-and-take; and a PA could not treat someone without the doctor having first established a relationship with the patient. But once that is done, many of the things that the doctor does can be done by PAs or residents. 111. Mr. Hackett's said that he saw an advertisement for a PA job at the Ottawa Hospital and that he was interviewed for that position by doctors, and that he deals with the Hospital’s human resource department in relation to employment matters. He is an employee of the hospital. But things like vacations are set in consultation with doctors and he gets compensating time off for any extra hours worked. 32 112. Mr. Hackett does not do what are normally considered managerial functions. He writes orders that require action by nurses and other employees, but he has no "managerial" authority to discipline anyone, or to direct someone to work over time, or to schedule a vacation. 113. Gabrielle Papineau is a PA in the orthopedic and spinal surgery department who entered the profession via a two-year PA program at the Mc Master University. She has no military background. She said that admission into the PA program requires two years of undergraduate training, but that most entrants have more education than that. She herself had a BA and an MA in kinesiology. She meets the CAPA competence profile. 114. Ms. Papineau described her role and her relationship with her supervising doctors in much the same way as Mr. Hackett did (although she is far less experienced). She has a "contract" with the supervising physician that essentially welds the two of them together - the doctor agreeing to supervise and the PA agreeing to assist on the basis of delegations from the doctor and "appropriate authorizing mechanisms". 115. This document has several interesting features and caveats. The PA is designated as the “agent” of the physician and is bound to provide patient care only within the doctor's own scope of practice (which presumably the PA is expected to know); and the PA undertakes to perform only those duties that are properly assigned or delegated. S /he is also expected to refuse duties for which she has not been adequately trained. 116. The doctor undertakes to provide direct supervision and to review the work of the PA and to be available for continuing consultation. However the document stipulates that there is no employer employee relationship with the doctor and it purports to disclaim any liability for anything done by the PA beyond the scope of his delegation. 33 117. Ms. Papineau described a range of responsibilities that are broadly similar to those of Mr. Hackett, but more narrowly focussed. That reflects her lesser level of experience and also her placement with doctors doing orthopedic or spinal surgery (different from what is done where Mr. Hackett works). In this respect she said that she may work with doctors and residents to do quite complicated things, like installing a Halo surgical traction device and putting in pins – something that residents do, but no paramedical employee does. She said that typically there are doctors there while she is doing this technique, but that she did it once on her own. The training to do that halo procedure came from a neurological nurse. 118. Ms. Papineau said that, at first, she worked very closely with doctors; but with increasing competence and physician comfort, she was delegated increasing responsibilities. She now sees patients on her own, she does patient work ups, and she develops plans which are reviewed by the doctor who decides what to do. She spends about two days a week in a clinic working directly with doctors, one day seeing patients on her own then discussing matters with doctors at the end the day, and one day in an operating room as part of the surgical team. 119. Like Mr. Hackett, there is a list of controlled acts that Ms. Papineau can do by delegation or by Medical Directives – which, as in Mr. Hackett’s case, avoids paper work and facilitates flexibility. Ms. Papineau said that an acquaintance, Jodi Paschal, a PA working in the orthopedic trauma area, has a different delegation checklist, reflecting different treatment techniques – again confirming that the PA role varies with the doctor to whom s/he is attached. 120. Ms. Papineau thought that if she lost her supervisor she would lose her job; but she noted that in the doctor's absence another one is substituted, so the relationship with particular doctor is not immutable or carved in stone. Another physician could step in. 34 VI – Doctor Kravcik’s perspective 121. Dr. Kravcik is a medical internist who practices at the Ottawa Hospital. He is part of a team that includes doctors and medical residents and medical students and PAs. Dr. Kravick has admitting privileges for his patients but he is not paid directly by the Hospital. I gather that he works on a fee for service basis and gets funds – colloquially, “health care dollars” - that are made available through the Ministry of Health or some other government or funding agency. 122. Dr. Kravcik said that his more seriously ill patients are likely to be assigned to “teaching units” were there are medical residents involved in their care. Medical Residents are doctors who are employees of the Hospital and provide patient care, but are also engaged in a program of continuing education through a University; so they will likely learn more from treating the more acutely ill. Less seriously ill patients are more likely to be cared for by PAs. 123. There are now four PAs in Dr. Kravcik’s group (the Division of General Medicine). Dr. Kravick said that the PAs decide whether a particular patient being transferred into their own orbit and whether they are comfortable with such assignment (recall that the PAs are not supposed to take on things that the y do not think they can handle) and that if the patient is struggling s/he can be transferred back to the teaching group. 124. From Dr. Kravcik’s perspective the PAs and the medical residents perform broadly similar duties. He said that the PAs were like a strong medical resident and that they play an important role in helping the doctors to manage patient care – shaping and channeling Dr. Kravcik’s own efforts, based upon the PAs judgment about when the doctor needs to be directly engaged. Dr. Kranchik said that the PAs do many mundane things (thus relieving the doctor of 35 those responsibilities) but that they can also do quite challenging things; and that they take the pressure off the physician - allowing the doctor to handle a larger number of patients. 125. Dr. Kravcik testified that a PA can be responsible for as many as 12 to 18 patients and that s/he typically works with several doctors - with a division of responsibilities that depends upon the level of trust and the PA’s demonstrated abilities. The PAs do whatever the doctor directs and delegates – working under the doctor’s scope of practice, as facilitated by Hospital Medical Directives. Those Medical Directives are signed off by the doctors in the medical department where the PA is situated and they increase the flexibility of the PAs role by removing the requirement for specific written authorizations (which is how Mr. Hackett described them as well). 126. However, Dr. Kravcik testified that any important work decisions would be discussed with him, and that after the fact he would typically ratify what the PA has done. As Dr. Kravcik put it, it was “his name on the chart”; and the degree of delegation and supervision and extent of physician-PA interaction, depends upon the patients’ needs, the parties’ comfort level, and the PA’s demonstrated skills. There is no guarantee of a particular volume or kind of work, which always originates with, and is funnelled through, the doctor’s own scope of practice. 127. Unlike the medical residents, the PAs are not involved in any medical training program (although the PAs do arrange their own continuing education); and according to Dr. Kravcik the PAs start from a broad but shallow knowledge of medical areas, which gradually expands with experience and becomes congruent with the scope of practice of the doctors for whom they working. They learn what the doctors do and expect in particular circumstances, and 36 they gradually take over part of that role – subject always to the doctor’s supervision, but freeing the doctor to concentrate on other matters or handle more patients or more clinics. 128. The PAs are moved around in accordance with need (like the residents are); and things like meal breaks, hours, or vacation time are worked out flexibly, as the needs of the department require. These issues - like so much else involving professionals - are worked out on a consensus basis. There is a high degree of cooperation and collegiality between the doctors and the PA and with other hospital employees with whom they interact. 129. Dr. Kravckik said that the doctor has to be satisfied with the performance of the PA and that any questions in that regard would have to be addressed by the doctor and by the medical department. The PAs have to get along with their supervising doctors. 130. However there were no concrete examples of such problems and there is no formal appraisal of the PA’s performance. Nor am I able to assess how frictions would be dealt with if the behaviour in question involved a PA and a paramedical employee or a nurse – although these employees have professional responsibilities too, and being unionized, would have access to a more formal process of review if the paramedical employee or nurse believed that the doctor or the PA was acting unreasonably or unprofessionally. A Regulatory College might also be involved if there were an issue about “proper delegation” or paramedical practice. 131. Since the PAs have no Regulatory College and are not covered by a collecti ve agreement, there is no similar basis, in their case, for an independent outside review. 132. However, this area of Dr. Kravick’s testimony involved the kind of "hypothesizing" that I referred to earlier. There is no actual evidence of any problems with a PAs performance, let 37 alone how they would be resolved, or who would be involved, or what remedial or other steps would be taken; and while it is no doubt true that the PA must get along with the physicians whom they assist, it is less clear what happens if they do not. 133. I think it is fair to say though, that if there were complete incompatibility or a relational breakdown with the supervising doctor, the department would have to find another PA and the PA would have to find some other doctor to work with. Or s/he might be “out of a job”. Because the PAs work is ultimately determined by the needs of the doctor and the department in which they are situated – although, like nurses, the PAs educational background means that they could move around or “assist” other doctors if t he “personal fit” turned out to be wrong. But given the PA’s status as a “contract employee” there is no guarantee of job security, regardless of who is “right” or “reasonable” in any given situation; and in this respect their situation is somewhat different from that of a unionized employee (although, to repeat, I had no actual example of what would happen if, for example, a paramedical employee could not get along with a doctor or a doctor thought that his/her performance was inadequate or inappropriate). 134. Dr. Kravcik explained that the use of PAs originated in a workload crisis some years ago when there were fewer residents than expected. The doctors had difficulty handling the work load and were forced to look for ways to off-load their less acute patients. Mr. Hackett was engaged at that time and the experiment was so successful that more PAs were hired. 135. Dr. Kravcik said that if a Department wants to add PAs to the team, that Department (and the Hospital) would have to “find the funding” for such positions. But it is quite unclear how this is arranged or what Hospital administrators are involved; and, it seems to have varied over the years as the use of PAs moved from the experimental stage to more regular use. 38 136. It suffices to say that the salaries of PAs seem to be supported by public "healthcare dollars" which ultimately come from “the government” or from outside funding sources of one kind or another; and the Hospital, as employer, is required to "find" the money once it is has been decided that another PA will be taken on – just like for any other type of employee or operational initiative for that matter. The hospital’s ability to self-fund is quite limited. 137. The selection of the PA applicant is largely controlled by the doctors in whose department the PA will be working. 7 However in a general sense all employees – including new employees - are funded from “health care dollars” and “funding pockets”; and the hospital has to secure funding and manage its budget to support its programs and those who staff them. 138. It is clear that Physician Assistant would not have a job unless there were one or more doctors willing to work with that PA and there was “funding” for the position; and further that, as the doctor’s surrogate in many ways, there has to be a high level of trust. But not only was there no actual evidence that a ruptured personal or professional relationship has led to any adverse employment consequences for a PA, Dr. Kravcik testified that whether a particular physician "takes on" a PA is not really a matter of choice. The PAs are now an integral part of the health care team in some areas of the Hospital; so that a doctor could not be part of that group unless s/he was willing to make use of, and work with, a PA. In this respect the PAs are part of the human infrastructure supplied by the Hospital – like the nurses or paramedical employees who also work with and assist doctors in various ways. 7 For example, the evidence is that there have been grants funneled to the Hospital though the Ministry of Health to pay for PAs but it is unclear whether or how some of the fee-for-service payments earned by the doctor (who can now take on more patients and run more clinics) can be used for this purpose; and I am told that there were ongoing questions about whether the doctors can bill for work that is actually done by the PAs. Ms. Pa pineau believed that the funding for her position was 50 % for the Ministry of Health, 25 % from doctors and 25 % from the Hospital; and that was Mr. Hackett’s view as well. 39 139. Dr. Kravcik said that he had no involvement in setting the PAs terms or conditions of employment or administering employment-related matters (like whether a PA gets T4 for income tax purposes). Similarly, while he thought that his own liability insurance covered the work of the PAs, he thought that they also had their own insurance - although he did not know who paid for it. (Mr. Hackett said that it was the Hospital that provided the insurance). 140. In summary then, Dr. Kravick said that, in his view, the PAs have a broader focus and more continuous involvement with patients than the "silo" employees do – similar to that of a medical resident. As Dr. Kravich described it: the PAs look at and work with the whole plan of care; rather than the pieces of it performed by the paramedical specialists. 141. However, unlike the medical residents – who are doctors in their own right and have the authority to write orders or direct patient interventions – everything that the PAs does is accomplished by delegation or by pre-authorization under a specific “Medical Directive”. Dr. Kravcik’s metaphor was that of “pilot and co-pilot”. VII - The PAs terms of employment 142. The PA's were hired individually as the Hospital determined its needs and worked out the availability of funding for each of the new PA positions. There are now six PAs (Mr. Hackett was the first). In each case, there were individual discussions with each prospective employee, and the result of those discussions was embodied in an exchange of documents, on the Hospital’s letterhead, making an offer of a two -year contract of employment, with the possibility of renewal and extension (which is what happened). 40 143. Apart from that temporal limitation, though, the PAs terms of employment are not fundamentally different, in kind, from those that one finds in the Collective Agreement – although less generous in some ways, and less detailed, and (arguably) less restrictive than the collectively-bargained provisions, and certainly giving the Employer more leeway to take unilateral action in accordance with its own needs and corporate policy. 144. The PAs terms of employment are administered b y the Employer's Human Resources Department (as is the case for bargaining unit members) and they include fairly standard things like a probation period, (longer than the one in Article 11.01 of the Collective Agreement), a basic 37.5 hour workweek (just like the one in Article 17.01 of the Collective Agreement), a stipulated salary (described for Mr. Hackett as an annual salary and for Ms. Papineau as an hourly rate – but, in form, not unlike those found in Appendix A of the Collective Agreement). There is also a series of formalities that have to be undertaken by the PA prior to commencing active employment, just like any other employee: a criminal record check, confirmation of his/her educational requirements, and some mandatory health screening that is performed by the Hospital’s Occupational Health and Safety department. There is "new employee checklist" that has to be followed and some payroll documentation to be signed. 145. The PAs have a schedule of benefits types (extended health care, dental, group life, accidental death and dismemberment, etc.) that are mandatory and are broadly similar to those that are customarily dealt with in collective bargaining and are applicable to bargaining unit employees. For example, vacation leave arrangements for the PA’s include a component for educational leave – recognizing the importance of continuing education for these new professional employees. And so does Article 15.06 of the Collective Agreement, which deals with “Education Leave” and Article 25.01 which deals with “Professional Development” and 41 Article 25.02 which deals with “Continuing Education”. In Mr. Hackett's offer letter he was advised that "you will fall under the entitlements and working conditions as outlined in the Terms of Reference and Working Conditions for Management 1 and non-union Professionals.” 146. Accordingly, while the PAs terms of employment are embedded in individual contracts (with the strong flavor of a contract of adhesion) the subject areas canvassed in that documentation are not materially different from those that are canvassed in collective bargaining and in the Collective Agreement (which is also a contract of adhesion, of sorts). It is just a matter of which “group” the PA is assigned to; and in neither case does s/he have much personal say in the matter. S/he has little choice - other than quitting and going to work elsewhere. 147. To be sure, the collective bargaining regime and the individual contract regime obviously have different legal characteristics. However, in practical terms, the PAs do not occupy an alien universe insofar as their terms and conditions of employment are concerned. Their terms of employment generally resemble those of their paramedical co-workers – with less job security, and, on the evidence, a salary that is lower than it would be if their work contribution were objectively evaluated in the manner that is required for bargaining unit members (see Ms. Cornick’s evidence below) VIII - What some “paramedical” employees do: the job duties of the comparators 148. The paramedical employees who gave evidence are not medical doctors. They do not do the range of things that medical doctors do, nor do they do what PAs do; and while they certainly work with doctors in various specialties and in various contexts, they are obviously different from PAs, and they are equally obviously different from one another. The umbrella word “paramedical” embraces profound differences as well as some broad similarities. 42 149. These paramedical employees typically work in what the witnesses described – I think accurately - as professional “silos” (not unlike the professional specialties in which doctors themselves practice); while, by contrast, the PAs start as generalists, whose delegated duties gradually come to resemble those of the doctors for whom they become the “surrogate”. The PAs adapt themselves to the doctors’ needs – the better to relieve those doctors of patient responsibilities, by delegation, and via Medical Directives that reduce the need from direct doctor intervention. Thus the PAs scope action and their ability to address patient needs is broader than that for any of the individual paramedical employees from whom I heard evidence. 150. The paramedical witnesses also address patient needs. But they do that through the lens of their own professional speciality and with a more focused expertise However, in many cases they derive their “work” from doctors like PAs do, and they must conform to the doctors directions; moreover their “silo” may be congruent with that of the doctors with whom they work (the Psychiatrist and the Psychologist for example, or the Chiropodist and the Physiatrist). They are separate paramedical professions with an independent scope of practice, but they work within a sphere dominated by doctors, and (in treatment terms) they are subordinate to them. 151. To be clear: there is no dispute that the PAs are a new and different employee classification; and no one says that the PAs particular mix of duties (reflecting those of “their” doctors) is the same as that of any pre-existing paramedical classification. They truly are a “new” and emerging professional group - even though they are not regulated under the HRPA. Moreover I think the evidence shows that the PAs have a much wider range of professional and medical responsibilities than any of the paramedical employees who gave evidence. I agree with the Employer’s submission in that regard. 43 152. It is evident therefore that a PA (like Mr. Hackett who was a highly qualified example) may do a number of things that may be different (a little or a lot) from the paramedical comparators who gave evidence: a Psychologist, a Chiropodist, a Respiratory Therapist (RT), an Advance Practice Physiotherapist (APP) and an Anaesthesiology Assistant (AA). For example: he could write a DNR notice, represent the doctor in family meetings, communicate the diagnosis of a terminal illness to the patient or his family, “run” a “code blue” (which is a term used to describe a patient who requires resuscitation or is in need of medical attention – often as a result of respiratory failure or cardiac arrest). The PA could help channel patients from the doctors teaching team to the PA team, do pre-operative work ups, or prescribe fluids for blood pressure issues, or order up imaging or other diagnostic tests. And the RTs, for example, did not do any actual surgery in connection with intubation or opening an airway. 153. However, the question in this case is not whether the PAs are “generalists” or “specialists” or “different” from other employees, or a “new” and different “profession” in the hospital environment, or more responsible than paramedical employees for particular kinds of treatment or for patients in general - but rather whether the PAs can be fairly said to be “paramedical” employees within the meaning of the opening words of Article 1.02. The case is about what kinds of employees participate together in collective bargaining - not the outcome of that collective bargaining, or the content of the work that the employees are expected to do, within the “scope” of their own “practice”, or how they go about doing that work. 154. And with that in mind, I think that the evidence of the “paramedical” witnesses, does help to illustrate the elasticity and inclusiveness of the word "paramedical" (and thus arguably informs its meaning); and also that it may provide some perspective on the (allegedly) 44 critical distinction between "medical duties" and "paramedical duties" – the distinction that the Employer says is absolutely central to the interpretation of Article 1.02. 155. The evidence of these paramedical witnesses was tendered for that illustrative and contextual purpose. However, despite the way in which the Union has developed its case, I think it is sufficient to take the "broad brush approach" that (in my view) is also called for, and reflected in, the word "paramedical" itself. Doctor Gretchen Conrad – Staff Psychologist 156. Dr. Gretchen Conrad is a Staff Psychologist who runs programs for patients who present complex and difficult behavioural and mental health problems. Her role is to facilitate the treatment of those patients/clients; and in that capacity she exercises a range of professional and leadership responsibilities, including: direct therapy, coaching and counseling subordinate staff, some budgetary involvement, and participation on a number of hospital committees. 157. Dr. Conrad does psychological assessments and provides psychological services in accordance with the needs of the patient and the standards of practice of the College of Psychologists, of which she is a member. She displays a considerable amount of independent judgment (i.e. she does not work only by delegation); and she noted that senior Psychologists may work with physicians and nurses and other healthcare and “helping” professions. 158. Ms. Conrad has a PhD in clinical psychology which she earned after many years of study and clinical training; she has worked in a variety of diagnostic and therapeutic roles; and she is a member of a number of professional organizations (the Canadian Psychological Association, the College of Psychologists of Ontario, and the Hospital Psychology Association 45 of Ontario). She is paid a salary, but she has worked under, and received, grants for research projects; she has attended numerous scientific and professional gatherings where she has made presentations; and she has authored a number of peer-reviewed papers (which she said is an expected part of her job). 159. She has also engaged in in-house policy review and program development; she has taught at the University of Ottawa (as she said at a number of Psychologist do - supervising graduate students); and she has been generally responsible for assessing the behavioral and mental disorders of clients, in order to make and communicate a diagnosis (which she is entitled to do under the RHPA). She said that at her level she did not get the easy cases, and that she participates in the diagnosis and development of a treatment plan, as well as the hands-on delivery of different kinds of therapy. 160. In order to maintain her license, Ms. Conrad was required to do written examinations and she is required to be familiar with about a dozen pieces of legislation. The College defines the areas of competence in which the registrant must establish proficiency. There are specialties too; and in the course of her work, she is expected to consult with other healthcare professionals, just like doctors and nurses do. It is a “professional practice”. 161. Ms. Conrad testified that there is a collaborative relationship with psychiatrists (doctors in that specialty) because the patients present a variety of mental and psychiatric conditions (like bipolar disorder or depression or schizophrenia). She said that she has to interpret various tests, to analyze the symptoms and their severity, and to review the clients’ medical files in order to help figure out the origins of the behaviour being observed; and in that regard, she deals with the patient directly (e.g. taking a history). Psychologists typically work 46 with Psychiatrists – although currently she does not. In her present role she works with registered nurses (in the nurses bargaining unit) and with social workers (MSWs) in the paramedical unit. 162. Ms. Conrad said that developing a patient treatment plan is a collaborative endeavor, but that the medical aspects of treatment are managed by doctors, since she does not have the legal authority to prescribe drugs. However, she does have to understand the underlying science of mental disorders and she has to be familiar with the efficacy of medications which are discussed with the doctor. It is a College decision about who can prescribe drugs; and only a medical doctor (not a PA or a paramedical employee) can prescribe narcotics 163. In Ms. Conrad's opinion, the Psychologist and Psychiatrist are both mental health professionals, whose expertise and roles overlap – although their Regulatory Colleges are different and the doctors (being “consultants”) need not be direct employees of the hospital. Dr. Conrad also works with and supervises “psychometrists” who administer and interpret tests; and she has a degree of responsibility for their performance – although she said that work deficiencies or professional practice issues would ultimately go to the Chief Psychologist, who is a manager excluded from the bargaining unit. But the Staff Psychologist is responsible to monitor the proficiency of the non-registered personnel who are part of their team and there are professional reporting requirements. 164. Ms. Conrad conceded that a psychologist would typically only work with a psychiatrist and not with other kinds of doctors. She has never worked with a PA. However, a some psychological services can be provided without a doctor's involvement; and where a doctor is involved, she said that the relationship is a collegial one with each professional considering the patient from his/her own perspective - having regard to the expertise and input of the other. 47 165. Ms. Conrad indicated that she could be called into the "circle of care" for a patient by a doctor or a nurse, but that the treating doctor is the "most responsible" for patient care and that she is only responsible for the patient's mental well-being. That is the sphere in which she can act independently - although in practice she would always discuss the situation with the physician. She could not recall any instance were her recommendation was "countermanded". 166. The doctor is responsible for admission and discharge of the patient with psychiatric issues, but according to Ms. Conrad, it would not likely happen without a senior psychologist being involved. And some kinds of psychological therapy can be undertaken without any doctor’s involvement all. 167. Ms. Conrad said that she was not obliged to follow the direction of the psychiatrist and that she could ignore a psychiatric diagnosis, just as the psychiatrist could ignore her own. But in practice, questions of this kind were completely hypothetical, because of the collegial approach that all healthcare providers are expected to bring to their part of the treatment process. There is a high degree of collaboration and mutual respect for complementary professional roles. 168. Ms. Conrad said that psychologists do not make purely “medical” decisions because they are not physicians; nor (for example) do they have the legal authority to compel a patient to submit to mandatory observation or assessment (which as a matter of law is the role of a physician). She has no involvement with other diseases or disorders except to the extent that they may bear upon her particular area of expertise, and she only needs to know about pharmacology in connection with her patient/client’s psychological problems. 169. For example, she would not have any involvement with liver disease or problems with someone’s feet or hands – although it seems rather unlikely that a psychiatrist would either, 48 because the doctors also work in silos, while remaining “doctors” for the purpose of fee -for- service administration or any interactions with “the Government” as funder and paymaster. 170. Ms. Conrad does not do many of the things that, I was told, some PAs do. She does not write a DNR order; she does not represent the doctor in family meetings, and she cannot run a "code blue". Nor of course do the PAs do what Dr. Conrad does. 171. In short, Ms. Conrad is a highly educated and well paid mental health professional, and since there is no evidence that psychiatrists have PAs, I can only speculate about how she, or they, might interact if there was one on the scene. Ruth Thompson – Chiropodist 172. Dr. Conrad's professional practice involves mental and behavioral disorders. Ruth Thompson, the Chiropodist, is completely different. She works with feet. 173. Ms. Thompson works in a foot care clinic where there are orthotic technicians and a receptionist but no doctor or nursing support. Nor is there any direct supervision of her work. She has a Bachelor of Science Degree (which involved training in the biological sciences and a clinical placement) and like many other paramedical employees, she is regulated by a "College" which sets the licensing and competence criteria and conducts examinations to ensure that registrants meet those requirements. 174. Ms. Thompson’s scope of practice is determined by statute and it can be expanded from time to time to meet the expanding needs and capacities of the profession. Ms. Thompson said that this was currently being considered by the Health Professions Regulatory Advisory Council (the body that considered and rejected the PA's bid to become a designated health 49 profession); and that the HPRAC is currently considering whether to increase the number of “controlled acts” which a Chiropodist can do – including ordering and reading x-rays and blood work, since that information is useful for her practice and would facilitate the efficient treatment of patients. The role of paramedical employees evolves – just like that of the PAs. 175. Ms. Thompson said that she is able to independently prescribe certain medications (like anti-inflammatories or analgesics) but she cannot prescribe narcotics (nor can any non- doctor). However, while she can prescribe medications, she said that she cannot formally communicate a “diagnosis” to patients (which is a “controlled act”) – although she said that she always explains to the patient what the medications are for. 176. Ms. Thompson can also do limited kinds of surgical interventions which require that a “medical consent form” to be signed by the patient. She provides ulcer care which includes cutting tissue to promote healing and is done under local anesthetic. She has her own insurance and has insurance coverage with the Hospital as well – reflecting (as with other paramedical employees) the possibility that a negligent act might produce harm and therefore expose the health care worker or the Hospital to tort liability. 177. Patients are referred to the clinic by a doctor in the hospital or in the community; and in the course of her work, Ms. Thompson is required to review the patient's history, consider his/her overall health, weigh the importance of other medical interventions, and check blood flow, blood pressure, neurological status, feeling, and biomechanics. She has to apply her “scientific” and (para) medical knowledge to the case at hand. 178. Ms. Thompson does not require a doctor’s specific approval for the work that she does, or for the treatment that she provides, or for the drugs that she prescribes in the course of 50 treatment. However, she does work in cooperation with doctors (like physiatrists) and she attends a clinic with orthopedic surgeons. She noted that diabetes is a common cause of foot problems. 179. Ms. Thompson said that in the course of her work, there is lots of liaison and discussion with doctors - including with dermatologists - and that there was equally close cooperation with technicians who develop the special footwear or orthotic devices that are used to address the patient's foot problems. She writes the prescriptions for such supportive devices and she monitors the quality of the technician’s work. But if there is any dereliction of duty or remedial action required, that would be dealt with by “management”. 180. Ms. Thompson's scope of practice does not depend upon that of the doctors with whom she collaborates. But obviously, she does not treat conditions like heart or lung disease or hypertension; she cannot work outside her scope of practice without a doctor's delegation; and a doctor's direction can override what she might otherwise be inclined to do. But my impression of her evidence is that she mostly works independently and that her relationships with doctors are cooperative and cordial – like that of the other paramedical employees who gave evidence. 181. She does not represent doctors in meetings, or answer pages, or write DNR orders or communicate the diagnosis of a terminal illness to family members (all of which, it is said, at PA can do if so delegated). Nor can she diagnose or treat diseases like diabetes even though that might be the cause of the foot problems that bring the patient to Ms. Thompson's attention. 182. Her focus is feet; and if other problems arise (like an infection that becomes more serious despite the prescription of anti-biotics) then she refers the patient along to a doctor. A chiropodist would not be expected to do otherwise – just as a psychiatrist would not be expected to treat someone’s foot problems. 51 Linda O’Regan – Respiratory Therapist 183. Linda O'Regan is a Respiratory Therapist (“RT”), a 35 year employee of the Hospital, and a Union official; and in these capacities she has personal knowledge of the role of “paramedical employees” like herself. However, she has not worked directly with PAs and has no direct knowledge of their situation (other than from the documentation that describes it); so her observations in that regard have to be taken with a grain of salt. This is not a reflect ion on Ms. O’Rgan's credibility, but only that her source of her information is indirect; so her answers to propositions put to her by counsel (both sides) have to be considered in that light. 184. Ms. O'Regan has a gained a wide range of experience in all areas of the hospital, which she joined after getting post-secondary training as an RT. She is registered with the College of Respiratory Therapists of Ontario (CRTO) and she meets that body’s competence requirements – which are a condition of her employment. There is continuing education as the profession develops and RTs can participate in "rounds" for educational purposes lik e some other hospital employees do. 185. Respiratory Therapists are healthcare professionals (non-doctors) who participate in the assessment and treatment of cardiopulmonary disorders and other maladies that require them to maintain open airways. They assist with intensive care and surgery patients by providing life support for those who cannot breathe properly. RTs are present at high risk births, they help stabilize high risk patients, and (like Paul Aboueid, an Anaesthesiology Assistant who also gave evidence – see below) they assist anaesthetists (who are specialized doctors) in the operating rooms, by administering inhaled drugs and medical gases. In that role the RTs operate specialized equipment for which they have been trained. And they maintain open airways. 52 186. There are gradations of competence within the RT group and there are Medical Directives that permit them to act without a specific written order – something that Ms. O’Regan said is quite useful in a cardiopulmonary crisis, where it is important to act quickly to manage obstructed airways. She testified that certain techniques, like arterial punctures, were once done only by a doctor, but they can now be done by an RT, although this still requires a verbal order from the doctor (a notional “delegation”, but also illustrating that the "work" of doctors and paramedical employees can overlap). 187. Ms. O'Regan explained that she works under the statutory umbrella of the Regulated Health Professions Act and the Respiratory Therapy Act, and that within that framework there is a prescribed scope of practice. However, from time to time there are professional controversies (managed by the CRTO, the Regulatory body) about the intersection of the RT's role with that of other healthcare providers – like whether medical acts can be delegated by the (relatively) new Nurse Practitioners, or only by the doctor or dentist or midwife (who have their own Colleges and designated scope of practice). 188. I gather that there is some controversy about who has the legal authority to delegate medical acts to RTs and what formalities are required; and that these kinds of questions ma y also pertain to the new PAs. As I understand it, there is some issue about whether an RT can take direction from a PA (who is himself working by delegation) or requires a doctor's co-signature, and whether it can be provided after the fact. 189. But that is not an issue that I have be decide and is also pretty remote from the interpretation question that the heart of this case: whether a new employee group is, or is not, in a bargaining unit for the purpose of determining their salary and benefits. 53 190. There is no dispute, though, that RT's are authorized under Medical Directives to start certain kinds of medications immediately – a decision that the doctor reviews and according to Ms. O’Reagan, routinely confirms. 191. Ms. O'Regan said that she has never worked with the PA, nor was she able to say from her own experience how doctors and PAs interact with one another, or how "work" is delegated or divided between them. She conceded that a PA might be able to call in an RT, but she doubted that the doctor or a PA could do the work of an RT for technical reasons (because they could not run the equipment); and in any event, they all work together in a multi- professional team and the work is shared – especially in an emergency. 192. She could not say whether a PA could “order” her to do something; and it is hypothetical whether a PA could, or ever would, “order” a paramedical employee to do something that was not authorized by their scope of practice or a Medical Directive. Similarly, in Ms. O'Regan's view, the word "veto" struck the wrong tone because the working relationships are collegial, with each participant drawing upon and respecting the experience of the others. 193. Neither a doctor nor a PA needs to follow the recommendation of an RT who, in turn (and unlike a PA) has no link to the physicians’ scope of practice; however Ms. O'Regan agreed (based upon her knowledge of the jobs in the bargaining unit) that there is no single bargaining unit person who does the range of things that the doctor (and implicitly a PA) would do (in the case of the PA by delegation or via a Medical Directive) – such as ordering a wide range of tests, reviewing the test results, assessing the patient at the bedside, adjusting medication, doing discharge orders, constructing a comprehensive plan of care. Nor do paramedical employees "handoff" the patient to the staff doctor as the PA does when s/he leaves 54 the workplace. Ms. O’Regan agreed that the PAs (derivative) scope of practice is broader than that of the paramedical employees whose work is more narrow and specialized. Ms. O’Regan also agreed that the PA, as the doctor’s delegate, could probably interrupt what a paramedical employee was doing and tell him/her to stop until the treating doctor was consulted. 194. Quite clearly (and without belaboring the details) the RTs do not do things that PAs do – like conveying a terminal diagnosis to family, or constructing plan of car e – although the RTs do have a degree of responsibility for treatment within their own area, and the RT's do have Medical Directives that permit some independent initiative. Within that framework they can make recommendations but those recommendations need not be followed. Ernestina Alvarez-Weist – Advanced Practice Physiotherapist 195. Ernestina Alvarez-Weist is an Advanced Practice Physiotherapist (“APP”) and clinical specialist, who has been a Professional Practice Coordinator since 2013. She has a Bachelor of Science degree (which involved studying the biological sciences); she works under the auspices of the Physiotherapy Act; and she is an accredited member of the College of Physiotherapists of Ontario, which requires its registrants to have post-secondary education and a multitude of skills that are tested by examination. 196. According to a Hospital document describing Ms. Alvarez-Weist’s role, its purpose is to allow surgeons to see more patients and to spend a greater percentage of their time in operating rooms - reducing their work in outpatient clinics (by relying more on the Advanced Practice Physiotherapist). The Advance Practice Physiotherapist conducts post-operative reviews of patients who have undergone uncomplicated hip or knee surgeries and does triage referrals. So as with the PAs, the APP helps to free up physicians to do other things. 55 197. Physiotherapy is a branch of rehabilitative medicine aimed at helping patients maintain recover or improve their physical abilities. They treat neuro muscular and musculoskeletal problems, and aid in the treatment of cardiovascular and respiratory complaints – which involves the treatment of pain, disease, or injury, by physical means. They can work in a hospital or in the community as independent practitioners. 198. However, according to Ms. Alvarez-Weist the practice of physiotherapy is evolving, so that it now extends to the diagnosis of physical dysfunctions - which in turn requires the authority to order diagnostics (like x-rays or CAT scans). That is now becoming part the regulatory regime and scope of practice under the legislation; but Ms. Alvarez-Weist can do these things, in any event, because there is a Hospital “Medical” Directive that allows it. 199. Ms. Alvarez-Weist explained that there are subspecialties within her profession; there are evaluation processes and specialty certification; and that there is a professional association (the Canadian Physiotherapists Association) which works with the Regulatory College to establish appropriate professional standards. 200. Persons in the profession now tend to be quite highly educated. Ms. Alvarez-Weist noted that in a recent Hospital job posting for an Advanced Practice Physiotherapist (“APP”) the Employer was looking for someone with a Bachelor or Masters’ degree in physiotherapy, or a Masters’ degree with a focus on orthopedics and research, five years of orthopedic experience with patients, demonstrated knowledge and leadership abilities - that is, someone who could cope with the expanding responsibilities of the profession and work under Medical Directives, in an advanced scope of practice, that was beyond the normal range of lower level physiotherapists. 56 201. One of those Medical Directives notes that the APP will be able to review and interpret a patient's x-rays, to determine normal versus abnormal findings, to communicate any abnormal findings back to the orthopedic surgeon, and consult for outpatient physiotherapy on behalf of the surgeon. Similarly, the APP is expected to a perform preoperative assessment on behalf of the surgeon and to determine the course of action based upon that assessment, using specific tools that are used by surgeons and that are based on the surgeons’ usual course of action – that is, for this purpose, they stand in the shoes of the surgeon, to some extent, and do what the surgeon might otherwise have to do on his own. The APP is also expected to do clinical visits to assess the surgical wound and the progress of healing, and to determine the course of action – which could include the removal of staples or the trimming of sutures. 202. When s/he is doing preoperative and postoperative assessments the Advanced Practice Physiotherapist has to review the patient's history, perform physical examinations, use diagnostic tools like x-rays, (which they can order themselves without a doctor’s sign off) and then prepare a plan of ongoing therapy or treatment. They do not attend the surgery itself; but they do help manage the consequences and participate in post-operative treatment. 203. They report to, and work with surgeons - helping to plan how best to meet the particular needs of the patients, and to facilitate whatever postoperative treatment might be required. They discuss these matters with the patient and with the doctors, and while the APP’s recommendations need not be accepted by him/her, they normally are; and they are sent to the patient's GP who is also involved in the outpatient follow-up. There is no reason to believe that the surgeon-APP relationship is any less collegial than all of the others that were canvassed in the course of the hearing – even if it is not as “symbiotic” as that of a PA 57 204. The objective of the APP is post-operative rehabilitation to heal whatever has been injured or restore normal functioning. Physiotherapy can ameliorate such deficits (including alleviating pain); and insofar as the outpatient roles is concerned, the APP communicates on behalf of the surgeon, just as she can do follow-ups on his/her behalf. 205. According to Ms Alvarez-Weist, she works with doctors and residents and other paramedical employees, and that because of her Medical Directives she can initiate tests of various kinds (haematology, radiological, ultrasounds). She did not think that the person performing those tests could refuse her requests – but it has never actually been an issue. Her Medical Directives include a list of things that she can do; and with those delegations in hand, she conducts her practice in cooperation with the doctors with whom she is working. 206. The pecking order was much referred to in evidence, but the answer was always the same: the employees are health care professionals and they are expected to conduct themselves is a professional and collegial way. And in the end, the doctors’ direction prevails unless it is contrary to some regulatory requirement. 207. Ms. Alvarez-Weist said that there are in-house tools that are used by the surgeons to assess her own competence – without which she could not hold her position at the hospital. However, since she also has an independent status as a health care practitioner, with a statutory scope of practice, and she said that she could also work in the community (which a PA cannot). She identifies the need for drugs but is it is the doctor who prescribes them (she said that she could prescribe analgesics on her own but has never done so); and because the patient is returning to the community she and the social workers work together to smooth that return. 58 208. Alvarez-Weist also has a number of administrative responsibilities, working with the "manager" to discuss and develop treatments, to provide education, and to deal with professional practice issues; moreover in that capacity (a job that was formerly called the "senior physiotherapist") she delegates work to others and supervises rehabilitation personnel. She is not a member of management but does play a “lead” role in her professional group. 209. Ms. Alvarez-Weist agreed in cross-examination that it is a doctor that brings her into the picture in the first place and that defines what is needed; and that the scope of her practice is confined to the statutory parameters unless augmented by the Medical Directives which permit her to do particular controlled acts. But since she and the doctors work together, under the same roof, in continuous cooperation, the metaphor of the doctor “opening the door” into the circle of care, is a bit artificial. It is not as if surgeons can easily go anywhere else and the Medical Directives mentioned above, specifically contemplate cooperation with surgeons. 210. Ms. Alvarez-Weist provides hands-on treatment of various kinds in response to the infirmities caused by whatever maladies bring the patient within the scope of her expertise. But she agreed that it is the treating physician who is most responsible for the patient and who can undertake an independent assessment of the diagnostics which may trigger a response on his part or prompt him to send the patient somewhere else. The doctor is also the one who is primarily responsible for addressing the underlying medical causes of the patient’s condition, and if there are oddities or abnormalities, it is the doctor who must ultimately decide what to do about them. If she, herself, detects something beyond the scope of her practice (like something she sees on an X-ray) she goes back to the doctor to discuss the matter and decide what to do next. The doctor is responsible for the total care of the patient and the Physiotherapist neither trespasses on that terrain nor would countermand a doctor's direction. 59 211. Ms. She said that her duties overlap with those of nurses, but by and large, her work is confined to her own area. Ms. Alvarez-Weist has not worked with PAs and has no direct knowledge of their role. Nor can she do things like "running a code blue”, writing a DNR notice, or conveying a "terminal illness" to the family – as opposed to postoperative regimen that the patient is expected to adhere to and which Ms. Alvarez-Weist arranging for. 212. She has no “contract” with a particular doctor – although she necessarily works routinely with selected doctors or residents because of the nature of their practice and her own. Paul Aboueid – Respiratory Technologist and “Anaesthesiology Assistant”. 213. Paul Aboueid is an Anesthesiology Assistant (“AA”). The College of Respiratory Therapists of Ontario (CRTO) describes the role of an AA as follows: Generally, AAs assist anesthesiologists in the provision of anesthetic care. AAs provide conscious sedation in consultation with the supervising anesthetist and can relieve an anaesthetist, caring for an uncomplicated stable patient during routine surgery for short periods… The AA participates in preoperative assessment, anesthetic care planning, pre-anesthetic preparation of the patient, anesthetic induction, monitoring and emergence, and postoperative anesthetic care. They insert and remove lines, apply and discontinue monitors, intubate and extubate, administer drugs, monitor patients (including procuring lab samples) and interpret vital signs and tests, support vital functions, recognize problems, initiate resuscitation measures and maintain equipment….to perform these activities they may require considerable knowledge and skill and clinical judgment. 214. Mr. Aboueid was initially trained as a Respiratory Therapist (with a post-secondary education like that of Ms. O'Regan) but he later took advanced training to become an AA – a new position that was developed in consultation with doctors. Mr. Aboueid testified that in order to become an AA, one has to be either an RT or a Registered Nurse with two years of critical care experience. His own educational upgrade involved many weeks of classroom and clinical 60 training - including working side-by-side with anesthesiologists doing different kinds of surgeries, using different kinds of chemical agents. There are formal training programs for AAs at Algonquin College and at the Michener Institute in Toronto. 215. Mr. Aboueid testified that as an AA he works on a rotating basis in different operating rooms at the hospital, where he encounters a range of patients with many kinds of vulnerabilities. He does not specialize in any type of surgery. He does what the CRTO profile provides for: he administers drugs or gasses, starts IVs and lines, and works closely with the doctors, providing another set of hands for the work that has to be done. In the Riverside location, for example, there are four operating rooms and five Anesthesiology Assistants, who work with patients and with a number of doctors who work in these operating theatres. 216. AAs take histories, respond to issues like an erratic heart rate, watch for complications, do sedation or nerve blocks and generally do a lot of the hands-on work, working side-by-side with the doctor. For example, Mr. Aboueid said that it is AA or the medical residents who put in the lines – not the nurses; and that the AAs administer medication of various kinds including blood pressure drugs. They do not introduce a general anesthetic without the doctor being present, but they can use other agents (under their own scope of practice) and (he said) they can “delegate” things to nurses. There was no evidence about how that works. 217. Mr. Aboueid explained that administering medication is a controlled act and that while he can do a local anesthetic on his own, a doctor must be present for the general (which is more dangerous). He said that he needs a doctor’s delegation to do spinals, central lines or epidurals (the doctor authorizes such actions and he performs them with the doctor present), but that he can carry on, on his own, if the doctor is called way to deal with some pressing matter in 61 some other area of the hospital. The AA is responsible for the patient during that interlude, but he would discuss the situation both before the doctor’s departure and after his return. The AA also carries out various checks and reversals before the patient is sent off to the recovery room. 218. Mr. Aboueid said that in the course of his work there are lots of possible complications, which have to be responded to immediately to avoid injury to the patient (like brain damage) and that the medications that he works with can be quite dangerous. He thought that he would be able to call for outside help (like a code) or deal with emergency situations on his own, but he noted that there were a number of professionals in the operating room with him, including the surgeon, registered nurses and medical residents. Surgery is a team exercise and the most experienced and responsible person would likely take over in an emergency. 219. Mr. Aboueid testified that patient vulnerabilities are identified prior to the surgery and that he works with all levels of risk. There are lots of preoperative tests (bloodwork, cardiology, allergy tests) that predict patient stress, but that is the doctor’s bailiwick and the doctor’s views on such matters will always prevail. As with so many other paramedical employees (and the PAs) the AA has a Medical Directive which authorizes what controlled acts he can do and what medications he can access (with, or without, formal authorization or delegation). And as with other paramedical employees, the Medical Directive relieves the doctor of the need for individualized authorizations and facilitates treatment techniques with which the paramedical employees are familiar. RTs can give some drugs in an emergency situation. 220. Mr. Aboueid said that if the patient's needs are beyond what is envisaged in th e Medical Directive, the matter is discussed with the doctor - otherwise he follows the Medical Directive; and that if there is a problem, then the doctor becomes involved. The Medical 62 Directive simply relieves the AA of the need for immediate physician in volvement and papweork; and according to Mr. Aboueid, if the doctor trusts the AAs judgment, then he may simply tell him to carry on. The doctor need not step in to do the procedure himself. 221. Mr. Aboueid said that he works with “learners” of various kinds, including nursing and medical students and medical residents, because he has developed considerable proficiency in his own professional niche; and that these learners do some kinds of work under his license and supervision. And since Mr. Aboueid is also an RT, he may be involved if there are airway problems that require attention or intubation. 222. Mr. Aboueid said that spinal and epidural and central lines can be done without the doctor being there and that other hospitals do this; although for present purposes, I do not think that I have to dissect the precise lines of authority, nor plumb the Regulatory College controversy about whether Acute Care Nurse Practitioners can “write orders” authorizing RT's to do controlled acts. It suffices to say that Mr. Aboueid is a paramedical employee with an extended scope of practice, who has been given responsibility under Medical Directives to do what needs to be done, and that those Medical Directives make it easier for the doctors to do their job without cumbersome authorizations. 223. Mr. Aboueid testified that the AA is a relatively new classification (dating only from about 2006) and that his relationship with doctors varies with their comfort level. Some doctors are inclined to delegate while others are not; but he remain s liable for errors under his own license, which is why he carries his own insurance (there is Hospital insurance as well). 224. Since he was also an RT, Mr. Aboueid noted that there are subcategories within the RT specialty and some of the RT's have administrative responsibilities; however the primary role 63 of the RT is described by the hospital this way: the RT is (according to a Hospital document) “a crucial member …and integral and valuable part of the operating room surgical team… [who] monitors patients during general anesthesia, regional anesthesia or conscious sedation through medical directives …while being under the supervision or close availability of the staff anesthesiologists” (which is consistent with Mr. Abouid’s testimony that he can continue to work on his own when doctors are called out of the operating room). And while the job title refers to “Assistants” it is clear that there are important functions that Mr. Aboueid does on his own (such as the insertion of devices and tubes and catheters, and central lines) – although always subject to the doctors’ review and potential override. 225. The AA, works under his registration with the College of Respiratory Therapists of Ontario registration; and it is interesting to note that the CRTO has a discussion paper that describes the AA as a "physician extender" – a paramedical employee who takes on additional responsibilities, which allows the anesthesiologists to be more productive, and a word that was used in this proceeding to describe the role of the PAs as well. 226. Mr. Aboueid said that what he does is similar to that of medical resident, but that there are differences too, because, being doctors, the medical residents may be able to do general anesthetics on their own, while the AA needs specific delegation. Mr. Aboueid testified that while he and a resident have overlapping knowledge and experience, they are not on the same hierarchical level because the residents are doctors who can write orders on their own. 227. Mr. Aboueid agreed that the RT training is specifically focused on respiratory matters and that it is different from that of a resident, and also that resident rotations are not the 64 same as RT rotations. In this respect, he works in a professional silo (as presumably does an anaesthesiologist – a medical specialty for the physicians). 228. Mr. Aboueid also agreed that there is no direct “doctor-patient relationship” between himself and the patient, and that any history or assessment that he does, is done on the day of the surgery when he first becomes involved. He does not order testing for the purposes of diagnosis, and by the time he comes into the picture the patient has already been seen and assessed by doctors who may or may not choose to consult with others. The doctors do not consult with the AA except in connection with the surgery itself. The AA is essentially a trained surgical functionary working in the operating room. He is not a doctor. 229. It is also clear that the doctors are the ones most immediately and intimately involved with the way in which the surgery unfolds – which is why the Medical Directives contemplate consultation and the doctor must be there to get certain things started. Mr. Abouid said that surgery - including calls for help - is team effort and in practice the person with the most experience or responsibility (normally the doctor) takes over. 230. There are lots of things that PAs or doctors do, that AAs do not do – although it is not clear whether PAs are attached to surgeons or anaesthesiologists, so the comparison is uncertain. However, Mr. Mr. Abouid conceded that he would not discuss or authorize a DNR direction, he does not attend rounds, he does not do pre-op consultations or pre-op directions, and he doesn't prescribe fluids for blood pressure issues, or order up imaging, or do any actual surgery to open an airway. So, for example, I do not know if an anaesthesiologist writes DNRs. 231. Moreover the relationship between the surgeon and the anesthesiologist present (the two doctors) may also shape the way in which things unfold in the operating room. Mr. Abouid 65 also agreed that when he is called upon to act in a crisis, it takes the form of structured algorithms that have been worked out in advance; so that he is implementing prescribed protocols, in the nature of a decision tree. The AAs personal judgement is channeled by these algorithms and if the patient is “crashing” it is the doctor or resident who steps in. 232. Mr. Abouid confirmed that an RN can do some of the work of an AA; but he said that only AAs can run certain kinds of machines. The AA works pursuant to his existing scope of (RT) practice, augmented by Medical Directives and delegation from the doctor. However, the doctors are under no obligation to follow the recommendations of an RT or AA and outside of the surgery itself the AA will not see patients. He has no role in treating an underlying disease like cancer (although the anesthesiologists may not either, since they too are in a medical silo). Nor do the AAs do discharge planning or write DNR directions or channel patients in to teaching or nonteaching streams – all of which, I am told, PAs can do. 233. Mr. Aboueid said that he is obliged to be a member of CRTO (which regulates the profession, investigates and disciplines members, and dispense advice on practice issues). He is also a member of the Canadian Society of Respiratory therapists – a private professional association established. In this he is similar to other paramedical employees – and to PAs. IX - Jen Cornick’s job and salary analysis 234. Jen Cornick is a human resources analyst who deals with job classification, wage analysis and pay equity issues. Ms. Cornick testified that for the purpose of this proceeding, she undertook an analysis of the PA position, based upon the (“CAPA”) Scope of P ractice and National Competency Profile (Exhibit 1), some information from Mr. Hackett, and a job description that was put together after the filing of the present grievance. 66 235. Mr. Hackett testified that this document does not accurately record his duties (recall that the role of the PA is something of a "work in progress"); however, in Ms. Cornick's view, these materials provided a sufficient basis for an analysis of the PA position, using a "pay equity tool" that she customarily uses to do job comparisons for pay equity purposes. The objective of this exercise was to examine the PAs job responsibilities in a systematic way, in order to see how the PAs might “fit in” with, or be compared with, members of the paramedical bargaining unit. 236. Ms. Cornick said that this pay equity tool (a kind of checklist) was not in fact used for bargaining unit positions because there was another, jointl y-negotiated mechanism in place; nor had the Union agreed that it would be used for job evaluation purposes or for establishing pay bands (which for newcomers, she said, would be done instead under Article 26.01). Nevertheless, in Ms. Cornick's opinion, the pay equity tool was a useful device “to shape her thinking" about how the PAs duties should be looked at, in a general way, and regardless of where in the hospital the PAs actually worked. 237. Ms. Cornick said that it informed her opinion about whether they were the “kind” of employees who “belong”, or ought to be, in the “paramedical” bargaining unit – that is, whether they were “like” these undoubtedly “paramedical” employees. 238. Ms. Cornick testified that she analyzed the PA's work, whom they interact with, their accountability and reporting relationships, the consequences of any errors (i.e. patient risk), their working conditions and the physical and mental effort expended in doing their jobs – all factors that (she said) are used in a pay equity analysis and that are also recorded in bargaining unit members’ job descriptions prepared by the Hospital. And in the end (like Dr. Krvacik) she 67 concluded that the PAs were acting more like a doctor or a medical resident (i.e. persons whom she regarded as “medical” personnel) rather than employees in the paramedical bargaining unit. 239. She also said that the PAs were paid roughly the same as what medical residents were paid - or perhaps a little more. 240. In Ms. Cornick’s view (and in comparison with paramedical bargaining unit members) the PAs could take more initiative in more medical or treatment areas, since they were not confined to a specialized silo as so many of the paramedical employees are – even if, like the Pharmacist or Psychologist (whom Ms. Cornick looked at for comparison purposes) the paramedical employees were well educated and had considerable ex pertise in their own sphere (e.g. the Psychologist can provide a diagnosis but cannot prescribe drugs; the Pharmacist has expert knowledge of drug options and efficacy but cannot actually prescribe them). 241. By contrast, the PAs were not discipline-specific and they had a more varied role in the plan of care and delivery of treatment - including doing diagnosis, consulting across specialties with the authority of the doctor (again if delegated and with the doctor’s input); and (she thought) they had the authority to accept or reject the input or recommendations of these other paramedical specialists, in the same manner as a doctor. 242. In Ms. Cornick’s opinion, the PAs had a more active role in ordering up particular diagnostics or directing the work of nurses (which was not how Mr. Hackett described his relationship with nurses); they had considerable independence in respect of consultation, coordination, and communication - including with patients and their families; they had a broader and more direct relationship with the patients; and they had more scope for independent action 68 (albeit always within the scope of the doctor’s practice and subject to his delegation and supervision and ongoing input). 243. The PAs had, in Ms. Cornick’s opinion, more diverse decision-making responsibilities, with the ability to seek advice and act on it - again like a medical resident; although, she noted that medical residents did not have the same relationship with physicians or patients because they are doctors themselves and were not restricted to the supervising doctor’s scope of practice. They had independent powers (as members of the College of Physicians and Surgeons) to prescribe or initiate action commensurate with their status as physicians; and they participate in their own “form” of collective bargaining, in a multi-employer format. 244. Ms. Cornick did not produce any arithmetic evaluation for the PAs (i.e. a “point score”). But she did testify that the PAs were "off the scale" in respect of their work responsibilities. She agreed that some of the paramedical employees were quite highly educated, but she said that the PAs had broader education rather than greater education. 245. Ms. Cornick conceded in cross-examination that it was quite difficult to evaluate the specialist jobs in the bargaining unit in relation to one another, and that the duties of the PAs and the paramedical employees overlap – just as (she said) was the case for doctors and nurses and residents, whose duties also overlap. She also testified that the “silo people” can do work that is within the doctor’s scope of practice (without having to be delegated); and that they have to acquire a lot of general medical knowledge too, even though it is only applied in their specialty. She also agreed that some of the paramedical employees can order up diagnostic interventions like x-rays, MRIs, or kinds of testing, if their scope of practice allows it. However, in her opinion, their diagnostic role was more limited and confined to their specialty. 69 246. Ms. Cornick's testified that, in her opinion, the PAs work responsibilities would produce a salary level beyond what was earned by anyone currently in the paramedical bargaining unit (hence her “off the scale” comment) – which led her to the conclusion that they were not the “kind” of employees who “should” be included in the bargaining unit, because they were not “like” those other bargaining unit members. 247. However, there is no evidence that this “tool” has ever been used to decide wheth er someone is, or is not, in the “bargaining unit” (i.e. to illuminate the meaning of the word “paramedical” or determine the composition of the bargaining unit); there is no language in the collective agreement which supports that proposition; there is no legal or other “rule” to the effect that the pay rate determines bargaining unit placement (which is about the right to participate in the bargaining process with other employees - not the result of bargaining in particular instances); Article 26.01 does not dictate where a newcomer will be placed in the salary hierarchy nor foreclose being placed at the top; there is a huge salary range within the paramedical bargaining unit already; and in fact, this objective and analytical approach was not actually used by the Hospital for the purpose of deciding what the PAs would be paid. 248. Ms. Cornick testified that there are "paramedical" employees who earn more than the PAs do (and thus, if she is right about the residents’ salaries, there are “paramedical” union members who are also paid more than some “medical” residents); and that when the Hospital was setting the PA salaries, there was no analysis of their comparative worth in relation to the other members of the health care team – whether in the bargaining unit or excluded from it. 249. On the contrary (according to Ms. Cornick) the PA salary was suggested by Health Force Ontario (which I gather is some government entity that has funding responsibilities) and 70 that is the salary that was offered to the incoming PAs; because, according to Ms. Cornish, the Hospital did not want to dip into its own pocket to pay them more. The PAs value to the organization, their clinical contribution to patient care, and their comparative worth in relation to other health care professionals, had nothing to do with it. 250. So, interesting as this discourse may be, it has not been used in the collective bargaining process, or for bargaining unit placement purposes, and it was not actually used in determining the PAs salary either. 251. What this evidence does show is that the PAs may be “underpaid” if their coworkers in the paramedical bargaining unit are used as a bench mark for objective comparison; and also that a medical resident (a “medical” doctor, doing “medical” duties, within the scope of his/her “medical” practice, and with the ability to initiate independent “medical” treatment) may be paid less than some mere “paramedical” employees - despite the fact that the residents also engage in their own form of collective bargaining. 252. It shows that whatever the alleged distinction between “medical” duties and (mere) “paramedical” duties may be, it does not translate, axiomatically, into a higher salary: for union members, a collectively bargained outcome. 253. Moreover the fact that Ms. Cornick can use a standard job analysis tool to project a salary level in this way shows that the PAs can be treated just like paramedical employees for compensation purposes. The PAs simply deploy a different mix of science-based skills and have different responsibilities – which are markedly different from those of the office & clerical employees or blue collar employees in another main bargaining unit (employees who are not involved in health care or treatment as the paramedical employees are and the PAs are). 71 X - Some general observations about the PA versus Paramedical comparison 254. It is clear from the foregoing that in terms of their work, the paramedical employees who gave evidence are quite different from one another and they are also quite different from the PAs. None of them do the same work as the PAs do, and none of them do the same work as their paramedical coworkers do; so that at this “micro level”, work-wise, they are hard to compare with one another – or with the PAs for that matter. 255. The evidence also shows that the PAs have more diverse responsibilities over broader treatment areas than the paramedical employees do – even if the PAs are not paid as much for what they contribute. That was confirmed by Mr. Cornick’s analysis. 256. However, if one shifts the focus a little, stepping back, and taking a more “macro view”, then there are a number of obvious similarities and points of comparison. 257. The paramedical witnesses all have post-secondary education in the biological and health sciences, and that academic training is necessary to qualify for their particular role in the treatment process. The same is now true for PAs like Ms. Papineau, who has had considerable academic success. In this respect, the PAs and the paramedical employees are all “knowledge workers” and that knowledge is rooted in the medical and biological sciences – as it is for the doctors with whom they work. They are not like the service employees or the clerical or administrative staff of the hospital who are in their own bargaining unit. 258. The paramedical witnesses are not doctors or nurses but they were all members of recognized “health care professions” which allow for a degree of independent action and professional responsibility – which in some cases permits them to engage in an independent 72 practice in the community. They are all recognized “health care professionals”, who not only have membership in a “Regulatory College” but are also typically members of outside professional associations that reflect their area of interest. They are not just “employees”. 259. But in my view, the PAs are “health care professionals” too – even though their role is derivative and the PAs have not yet moved as far along the road to “professionalization” as some of the health care professionals in the paramedical bargaining unit have done. 260. It is true that the PAs currently have no statutorily-certified expertise or scope of practice pursuant to the HRPA or any other specialized legislation. The PAs are not, and cannot be, independent practitioners. But there is no doubt (in my view) that they are an emerging and recognizable professional group - hence the existence of College programs to teach students how to become a PA and the accepted CAPA National Competence Profile. The PAs have the trappings of professional status, even though they currently lack statutory recognition. 261. Accordingly, I think that the PAs and the paramedical witnesses are both fairly described as health care professionals – even though the HPRAC decided that no formal regulation was required for PAs because of the degree of supervision by the physicians. 262. Similarly, while the “work” of the paramedical employees is diverse, but it is ultimately derived from the treatment needs of the patients and allocated under the aegis of doctors, who are most immediately responsible for patient care. What the paramedical employees “do” depends to a significant extent upon what those doctors need and refer – doctors with whom the paramedical employees work, with varying degrees of continuity trust or independence, depending on their experience and their relationship. And neither the origin of that work or its nature is similar to the work done by service or administrative employees. 73 263. In this respect the paramedical employees are also professional health care auxiliaries, doing things that assist the doctors, or instead of the doctors, but almost always subject to the doctors’ professional judgement and prescription. 264. But the paramedical employees work with and for doctors too – taking directions and shaping their response to the needs of the patient as interpreted, ultimately, by doctors. 265. The “role” of the PAs and the paramedical employees are both subordinate to that of the doctors – even though the PAs and the paramedical witnesses both provide their own direct “hands on” treatment for the patient. But it is the doctors who the most direct “legal” relationship to the patient and the most responsibility for patient care (although it would not be surprising if a physiotherapist, for example, spent lots of hours interacting with the patient). 266. The paramedical employees may have some statutory independence, certification and authorization to do particular treatment functions and the PAs do not, but in both cases their role is derivative in this sense. They are professions that are organized around and subordinate to the medical profession. And because the paramedical employees work in silos, they have a direct and continuous relationship with a particular sub-set of doctors – a relationship which all the evidence shows is cooperative and collegial, just like that of the PAs. 267. In the result, there are some general observations that apply to the paramedical employees and the PAs alike – although the PAs have a closer and more continuous and intimate and symbiotic relationship with “their doctors” than the paramedical employees have with theirs, and the PAs have more, and broader, responsibilities for patient care. The PAs work “hand in glove” with the doctors in a way that is different from that of the paramedical employees from whom I heard evidence, even though latter work closely with doctors too. 74 268. However in my view, these are matters of degree, not kind; and they arises because everything that the PAs do is delegated and they have no independent professional authority to do anything other than what the doctor directs or delegates or authorizes them to do. 269. And of course, none of this has anything much to do with employment law or collective bargaining - which is one way in which terms and conditions of employment come to attached to groups of employees. And the fact is: the actual terms and conditions of employment for the PAs are broadly similar to those of paramedical employees, even though the latter are negotiated, while the terms of the PAs are imposed more or less unilaterally by the Employer. 270. Moreover, in both cases the PA employees are (for many employment matters) being treated as part of a group - just as the paramedical employees are being treated as part of a group for employment law purposes (in their case, a “bargaining unit”). 271. For despite having many different and very responsible work functions, the PAs salary and benefits are broadly similar to those of the paramedical employees. That is why Ms. Cornick had no difficulty matching the PA’s job duties with salary outcomes based upon a comparison with the paramedical group (although she was discomfited by the result). 272. The PAs are not like doctor-consultants who work on a fee-for-service basis, nor are they like medical residents whose terms of employment are intertwined with their role in an ongoing university education program (which is reflected in the multi -employer bargaining in which the residents are engaged). 273. The PAs are just “employees” whose terms of employment resemble, in broad outline, those of their paramedical coworkers – who may get paid more than the PAs do. 75 XI - The Position of the Parties restated UNION ARGUMENT 274. The Union contends that the word “paramedical” in Article 1.02 has to be interpreted in light of what might be described as its utilitarian “collective bargaining meaning” – a meaning that (according to the Union) is informed by the way in which the word “paramedical” has been used in the labour relations world to describe this particular kind of bargaining unit (especially by the OLRB when it creates such units), and by the way in which the parties themselves have grouped together so many different kinds of health care professionals, for bargaining purposes, in the “paramedical” unit. 275. In the result, according to the Union, the word “paramedical” refers to an eclectic grouping of professional, scientific and technically-trained health care employees who provide medical services for patients, but who are not doctors or nurses. And in the Union’s view, that word - “paramedical” - reasonably describes the newly hired PAs. 276. The Union argues that its proposed interpretation is consistent with the normal “rules of interpretation” and with dictionary definitions of the word “paramedical”; but more importantly, it reflects the normal composition of this particular kind of hospital bargaining unit as well as the particular example of it found at Ottawa Hospital. 277. So while it is true that the disputed PA job did not exist when the paramedical bargaining unit was initially constructed, the Union submits that the word “paramedical” nevertheless embraces these newcomers – who (according to the Union) are broadly similar to 76 other “professional” and technical employees who are grouped together in the “paramedical” bargaining unit, for collective bargaining purposes. 278. The Union argues that in a general way and from a collective bargaining perspective, the PAs are like those other “paramedical” employees. Moreover, I have put the words “in a general way” in italics because, in the Union’s submission, that is all that is required, given the nature of this particular kind of bargaining unit - which reflects great diversity around a common theme. And that common theme (says the Union) is that it covers scientifically, technicall y, and professionally trained health care providers who are not doctors or nurses. 279. In the Union’s submission, that is what is meant by the term “paramedical”; and it distinguishes this broad swath of employees, from other employees, who are found in other kinds of bargaining units at the Hospital. And from nurses who have their own unit. 280. The Union notes that this kind of “generic” bargaining unit has been a feature of Ottawa Hospital’s collective bargaining environment for many years; and, in the Union’s submission, the general nature of that unit (science-based and very inclusive) points towards the inclusion of the newcomers as well. Indeed, the Union claims that the emergence of a new kind “paramedical” classification (who is not a doctor or a nurse) is precisely what the word “paramedical” was designed to capture, and what Article 26.01 of the Paramedical Collective Agreement specifically contemplates will happen from time to time. 281. The PAs are not managerial employees or otherwise statutorily excluded from engaging in collective bargaining; they are not blue collar “service” workers or office and clerical employees; and they are not nurses. Accordingly, in the Union’s submission the scientifically trained PAs fall naturally (i.e. as a matter of interpretation) into the “paramedical 77 group”, where there are other health care professionals, broadly like themselves. That is where their community of interest lies for collective bargaining purposes; and in the Union’s submission, the placement of the PAs in the “paramedical” bargaining unit (i.e. concluding that they truly are “paramedical” employees) is supported by both what the PA’s are and what they are not. The existing bargaining structure points to their placement in the paramedical unit. 282. Insofar as the collective bargaining meaning of the word “paramedical” is concerned, the Union urges me to adopt the following interpretation found in U.N.A. v. Calgary Regional Health Authority et. al. [1999] Alta.L.R.B.R. 458 - where the Alberta Labour Relations Board described the ambit of the word “paramedical” this way (emphasis added): The word “paramedical” literally means “almost medical” or close to medical, and in its broadest meaning encompasses anyone performing medical functions under the direction, supervision or authority of a physician. The word “professional” connotes advanced training, licensure, formal standards of practice and occupational self-government, all in varying degrees. The core idea of the paramedical professional [bargaining] unit then, is to recognize the community of interest of employees subordinate to the physician who perform medical functions and are organized to a significant degree according to a professional model. 283. The Union notes that this interpretation of the term “paramedical” is much the same as the one enunciated by the OLRB, twenty years earlier, in Stratford General Hospital Re Stratford General Hospital and Ontario Public Service Employees and Allied Health Professionals et al [1976] OLRB Rep. September 459 (see below); and in the Union’s submission, both cases illustrate the commonly understood meaning of the word “paramedical” - which is used in a generic sense to describe a particular kind of bargaining unit that is found in public hospitals. That is the way that hospitals have been subdivided from bargaining purposes. 78 284. The Union acknowledges that the work of the PAs is not the same as that of the other health care professionals who are already in the paramedical bargaining unit. However, in the Union's view, the fact that PAs have different duties is not determinative – not least because those other paramedical employees are all so different from each other. 285. The Union points out that the paramedical bargaining unit includes a hodgepodge of quite different health professionals who are all lumped together for bargaining purposes; moreover, as the Union sees it, the newcomers are not so different from these other health care employees as to be a different “kind” of employee altogether – a “medical employee” rather than a “paramedical” one (which is what the Employer asserts – see below). 286. In the Union’s submission there is no contractual foundation for the “medical” versus “paramedical” distinction asserted by the Employer; nor is there any evidence that the word “medical” (as opposed to the word “paramedical”) has that collective bargaining meaning in Ontario, when it is used in connection with bargaining unit descriptions or bargaining unit composition. Or that the parties themselves have made that distinction in their own local relationship. In the Union’s submission, the labour relations term for medical caregivers who are not doctors or nurses is the word “paramedical” – which is the word that is found in Article 1.02. 287. In the Union’s submission, the PAs in this case are, generically, “paramedical” employees, regardless of the particular mix of duties that are delegated to them by their doctor or by Medical Directives from the Hospital; and that is so, (according to the Union) even if they perform what might be fairly described as “medical functions” that might also be done by a doctor or by a medical resident. The PAs are the “kind” of professional employee described in 79 Calgary Regional Health Authority and Stratford General Hospital as “paramedical” for collective bargaining purposes. And that is the “definition” that the Union urges I accept. 288. In the Union’s submission, providing treatment or health care or performing what might be described as “medical functions” does not turn the PA into a doctor or a “medical” employee, for bargaining unit purposes. They are not some different “creature”, with a wildly different community of interest, who must bargain on their own, in their own little island, separate and apart from all of their professional colleagues. That is the very antithesis of what the comprehensive “paramedical” bargaining unit was designed to achieve; and that is why Article 26.01 envisages that new classifications will be rolled in to the existing salary structure. 289. In the Union's submission, the newcomers are clearly "employees" of the Hospital (which is not disputed); they are not employees of the doctors for whom they work; and their actual terms of the employment (i.e. what collective bargaining is about) are not substantially different from those of other professional employees who are in the paramedical bargaining unit. For example they have a standard 37 ½ hours per week work schedule, they have a normal kind of probation period, they have vacations just like other “employees”, they have group benefits; and so on. Moreover, their agreement with "the doctors" (as described in a Hospital Letter on Hospital Letterhead) makes it perfectly clear that while the Physician Assistants work with individual doctors and take instructions from them, they are “employees” of the Hospital. 290. The Union acknowledges that the PA’s arrangement with “their doctors” is a personal one with a strong element of trust, and that their work is shaped by what the doctor wants them to do and by what the Hospital’s Medical Protocols permit. But as the Union sees it, there are other “paramedical” employees who also have to adhere to hospital protocols and who 80 must (generally speaking), follow the doctors’ instructions and can do things by delegation; moreover, many of those paramedical employees must also maintain, as a condition of employment, a registered professional status that is statutorily prescribed and regulated. 291. The Union argues that there is nothing unusual about having a supplementary regimen that paramedical employees have to follow, despite also being covered by a collective agreement; and in the Union’s submission, there is no incompatibility between the professional responsibilities or a personal commitment to a doctor, on the one hand, and engaging in collective bargaining as part of the paramedical bargaining unit on the other. 292. Thus (so the Unions says), the personal work arrangements with the doctors or their departments do not prevent the PAs salaries and benefits – their terms of employment - from being established by collective bargaining (which is what a “bargaining” unit is for) any more than it prescribes what their benefits or vacation entitlements will be. The “contract” with the doctors does not touch these things. Nor does the nature of that work relationship with the doctors mean that the PAs are no longer “paramedical” employees of the Hospital. 293. The Union says that it is the employment relationship with the Employer that matters here; and that it is the Employer that sets the salary and other bargain-able conditions of employment whether the bargaining process is “individual” or “collective”. And collective bargaining for professional health care providers who are not nurses (or doctors or medical residents) is conducted under the umbrella of the “paramedical” bargaining unit. 294. In the Union’s submission, it would create no anomaly if the PAs’ terms of employment were negotiated collectively, in conjunction with other professionally trained health care providers who populate the paramedical bargaining unit – rather than, as in the present case, 81 being prescribed more or less unilaterally by the Employer. The consequence of the Union’s proposed interpretation is merely that the PAs will be treated like other health care professionals whom the Union already represents, and who, the Union says, the PAs generally resemble. 295. The Union notes that the newcomers are not covered by the Regulated Health Professions Act. They have no scope statutorily-rooted scope of practice or professional responsibilities. Their work is completely dependent upon what their doctor tells them to do and what their doctor delegates. They are not independent health care professionals or members of the College of Physicians and Surgeons or medical practitioners under the Medicine Act. 296. However, in the Union’s submission, the fact that they may perform “medical functions” hardly removes them from the “paramedical” employee category for collective bargaining unit purposes. On the contrary, their subordination to the doctor is similar to that of other paramedical employees; and it is that subordination and lack of true medical credentials that reinforces their characterisation as “paramedical” employee. 297. Similarly (according to the Union) being authorized or directed by a doctor to do something is no sign that the individual is not a paramedical employee; nor is that conclusion different simply because an individual has established trust and has therefore been allowed to work autonomously or with minimal direction. That is just a facet of professional status, which is shared by many paramedical employees - who are ultimately obliged to do what the doctor expects them to do, unless it collides with a regulatory limitation or hospital protocol. 298. In the Union's submission it does not matter that many of these other paramedical employees are quite specialized or work in silos, because, with authorization (similar to what the PAs need for everything that they do) bargaining unit members can work outside their silo too; 82 moreover, the PAs can also have a specialized focus depending on the medical specialty or scope of practice of the doctors for whom they work (e.g. Ms. Papineau who works in the orthopaedic - spinal area, doing different things than Mr. Hackett would do). However, in the Union’s submission, they are still part of the “paramedical” group - just like so many of the other “employees”, with quite differing skills, whom everyone agrees are “paramedical” employees. 299. In the Union's submission, the Physician Assistants’ education (currently four years of post-secondary education supplemented by didactic and clinical experience) is likewise not so different from that of many other paramedical employees - especially those at the top of the “paramedical ladder”. Counsel points out that a Physiotherapist, for example, can now have a four-year undergraduate degree plus an additional two year Master’s Degree. The Psychologist who gave evidence has a PhD. Many of the paramedical employees have advanced educational credentials of one kind or another, and many of them have had to study the biological sciences in order to qualify for membership and certification in their professional groups – just like the PAs. 300. The Union does not dispute that the PAs are highly trained and that once they are experienced and trusted, they will operate with a considerable degree of autonomy. Nor does the Union assert that other paramedical employees do what PAs do - or vice versa. 301. However, as the Union sees it, those are just badges of “professionalism” and specialization, which are shared by many paramedical employees with post-secondary education in the health sciences; and to the extent that the newcomers have this kind of educational background and autonomy it points to inclusion in the “paramedical” group rather than the reverse. It shows that the PAs are like their well-educated paramedical coworkers. 83 302. The Union acknowledges, and the Employer emphasizes, the extent to which the PAs do controlled medical acts (by delegation). However, according to the Union, regulated health professionals also do controlled medical acts (as the regulations in the Regulated Health Professions Act seems to recognize), just like the PAs. The PAs are not unique in this regard; and the PAs do not have full independence (let alone statutory authority) since they are always doing things by delegation. There are other paramedical employees who do controlled acts too, and whose prescribed scope of practice is supplemented by Hospital “Medical” Directives – which the PAs also require, unless there is a specific delegation from their doctor. 303. In the Union’s submission, these differing work and professional responsibilities are not critical distinctions for collective bargaining purposes – the purposive focus that the Union urges me to keep in mind when I am interpreting words in a “bargaining unit” definition. 304. More important (the Union says) is that all of the PAs (and many paramedical employees as well) work around, or in respect of, the diagnostic and treatment regimen provided for a patient and ultimately overseen by a doctor – a doctor who may or may not be an employee of the Hospital himself/herself. 305. The “paramedical” employees comprise a collection of separate occupations that are organized around and subordinate to the medical profession (just like the PAs are); they provide diagnostic services and treatment for patients; and they are customarily grouped together in a single large “paramedical” unit for collective bargaining purposes. This is a description that, the Union says, applies, equally, and quite naturally, to the newcomers. 306. The Union reiterates that this is what Labour Relations Boards “meant” by the word “paramedical” when they create such paramedical bargaining units; and in the Union’s 84 submission, an arbitrator should not disregard the themes that underlie the OLRB’s handiwork, or adopt an interpretation that could lead to a small island of collective bargaining (here only a handful of employees) just because the newcomers are “different” in some ways from existing bargaining unit members. The differences are not so profound that PAs are no longer “paramedical” employees. 307. The Union does not concede that the disputed individuals are just like “medical residents” - who are different from the Physician Assistants in a number of ways, including their professional objectives and status, and of course the important fact that they are medical doctors in training, who have their own multiemployer bargaining arrangements. However, even if the disputed individuals are similar to “residents” work-wise the Union argues that this points to their being classified as “paramedical” employees as that term is understood for collective bargaining purposes. Because the PAs are not residents. Nor does anyone suggest that PAs are part of the residents’ collective bargaining regime. 308. The Union points out that nurses are also involved in medical care; they work very closely with doctors (with whom their role overlaps); and in recent years, the nursing profession has spawned a new category of advance practice nurses, called “nurse practitioners”, who have additional education and accreditation, which allows them to do things that might otherwise be done, or once might have been, done by a doctor. They are thus in positions that are notionally “above” other nurses’ bargaining unit members. They are in a higher professional tier. 309. However, arbitrators have ruled that they are still “nurses” for collective bargaining purposes and they remain part of the nurses bargaining unit. 85 310. Having extra duties that might once have been done by doctors, doesn’t alter the fact that such employees are still in the nurses’ bargaining unit for the purpose of establishing salary and benefits. 311. The Union submits that the PAs should be looked at in much the same way. They remain “paramedical” employees even though their patient care responsibilities are different than, and perhaps broader than, other employees in the paramedical bargaining unit. And while their role may be more (objectively) critical or highly valued, those important and diverse responsibilities do not make the incumbents any less “paramedical”. 312. In summary then, the Union argues that when the word “paramedical” is read literally and in this collective bargaining context, it applies - and was meant to apply - to employees "like" the physicians’ assistants. The disputed individuals are “paramedical employees” who fall within the scope of Article 1.02. 313. In support of these propositions the Union referred me to a number of cases and materials which, I have listed in Appendix to this Award. It is conceded that none of the cases involve PAs, who are relative newcomers in the health care system. EMPLOYER ARGUMENT 314. The Hospital concedes that the Physician Assistants are "employees" of the Hospital; and the Employer does not take the position that they are statutorily excluded from engaging in collective bargaining (i.e. that they have no right to collective bargaining at all, under the OLRA, as is the case with doctors). 86 315. The Hospital does not say that they are doctors, or members of the medical profession in this sense, or that they are members of the College of Physicians and Surgeons either. As the Hospital sees it, the PAs can either deal with the Employer on their own, individually (the current model), or they could conceivably constitute a separate bargaining unit (represented by a union of their own choice). 316. But in the Hospital’s submission, they are not “paramedical” employees who are covered by any existing Paramedical Collective Agreement with OPSEU. They are, instead, “medical employees”, who are implicitly excluded from Article 1.02, and as things now stand, are non-union employees, whom no union represents. They are not “in” any bargaining unit. 317. The Hospital submits that the disputed employees work completely under the "medical scope of practice" of the doctors whom they assist and the "medical directives" emanating from the Hospital itself; so that these individuals are properly regarded as "medical" employees and not "paramedical" employees. And of course, if they are not "paramedical employees", then they cannot be in the "paramedical" bargaining unit or covered by the “Paramedical” Collective agreement. 318. In the Employer's submission, not only is the newcomers' scope of practice entirely "medical" in nature (being derived exclusively from that of the medical doctors to whom they are attached) but they do not work in specialized silos like so many of the “paramedical” employees do (including all of the Union's witnesses); moreover in the Employer view, the Physician Assistants have far more autonomy, spanning more "medical" areas, than a mere “paramedical” employee would have - which is not only reflected in what the PAs do, but also in the generalist 87 education that they have, which (counsel submits) has more in common with medical students and medical residents than the more specialized "paramedical" employees. 319. In the Employer's submission the "work" performed by the Physician Assistants (taking histories, doing diagnostics, ordering tests, communicating with patients instead of the doctor, putting together treatment plans, following through with the patients on their path to recovery or even declaring death) is all essentially "medical work" - meaning that the disputed individuals are "medical employees" not "paramedical employees". 320. For example, (counsel points out) Ms. Papineau testified that a Physician Assistant could drill holes in the patient's skull, insert pins or attach an immobilizing device, or do a “close” in the course of a surgery (something that Mr. Hackett confirmed too) – which are all medical acts; and, in the Hospital's submission, that supports the proposition that a PA should be regarded as a "medical" employee rather than a “paramedical" employee. 321. Similarly, the PAs review the charts and address issues arising with respect to a patient, adjust medication, and hand off problems to a doctor in the same way that a medical resident would do. Indeed, as the doctor’s agent or alter ego, what the PAs do (by delegation) is in all respects “medical work” (“doctors’ work”), so they should be considered to be “medical employees” not “paramedical” employees. 322. Counsel for the Hospital also points out that the only effective supervisor of the work done by a PA is the doctor to whom s/he is attached – a doctor who is not an employee of the hospital (which, it is said, makes PAs different from other hospital employees); and further that doctors use PAs and medical residents (fledgling doctors with an M.D.) interchangeably. 88 323. The Hospital submits that in functional terms the Physician Assistant is the day-to- day equivalent of an experienced medical resident (which was Dr. Kravcik’s evidence) who fills in for the Physician Assistants (along with doctors) when they are on vacation, just as Physician Assistants are used by doctors as an alternative to using a medical resident. The paramedical employees are not used interchangeably in this way – doing what PAs do, in their absence. 324. This shows (the Hospital asserts) that the Physician Assistants are, functionally, “medical” employees and not “paramedical” employees. They are the non-doctor equivalent of a medical resident. 325. Counsel points out that the PAs write out orders, write or contribute to treatment plans, check consults, and order patient transfers – none of which, counsel submits, is done by the paramedical employees. Medical disagreements or queries are dealt with by the doctors with whom they are associated. The PA also speaks for that doctor at meetings in respect of the patient's medical issues; and while a nurse may also be present at such meetings too, it is the Physician Assistant, in place of the doctor, who plays the “medical role” at such meetings. 326. The Physician Assistant can also co-sign documents for the doctor when authorized to do so; and s/he can communicate on the doctor’s behalf. They can even pronounce death or sign a death certificate when authorized by their doctor to make such call [the evidence was unclear in this regard]. And they can do DNR documentation as well. In counsel’s submission, this is all quite different from what other “paramedical employees” do; and constitutes “medical” functions rather than “paramedical” ones. 327. Counsel emphasizes that the Physician Assistant’s role in diagnosis and treatment is not limited to a particular silo like the paramedical witnesses who gave evidence. They are 89 doctor surrogates; they are generalists; so that when a registered nurse encounters a problem, she will likely call the Physician Assistant, who in turn, will decide whether to bring in a doctor. 328. Moreover, that is possible and workable because (according to Employer counsel) the competence profile of a Physician Assistant is similar to that of a medical resident - as is reflected in the document under which the Physician Assistant works. Furthermore, without the supervising doctor to take them on, they would really have no job at all (even though the Hospital is their employer and paymaster) – which in counsel's submission, is quite different from the paramedical employees who gave evidence. Their job is not tied to a person in this way. 329. Counsel reiterates that the medical directives and scope of practice under which the physicians’ assistants work, reflects the scope of practice of the supervising doctors; so that functionally, the Physician Assistant is interchangeable with that doctor or with a medical resident attached to the doctor. As he put it, the Physician Assistant is like a medical resident who never becomes a doctor (recall that a medical resident has an MD degree and is a doctor in training); while conversely, the PA is the doctor’s alter ego – with a delegated responsibility for diagnosis and treatment and the ability to initiate follow-up in a way that is very different from the far more specialized and limited role “paramedical” employees. 330. That is why (so I was told) the rating system used for salary purposes and pay equity consideration, scored the PAs above the maximum scale that is available for existing “paramedical” employees. Because in the Hospital's submission, the PA’s responsibility to the patient is virtually the same as that of the doctor – which is why Dr. Kravcik, one of the supervising physicians described that relationship as that of pilot and co-pilot. 90 331. In counsel's submission, the paramedical employees who gave evidence exaggerated their role and their contribution to patient care and their independence; but in any case, none of their testimony undercuts the Hospital’s assertion that the unique blend of functions undertaken by the Physician Assistant, under the aegis of the doctor’s medical scope of practice, makes the Physician Assistants "medical employees" and not "paramedical employees". Performing “medical” functions is the essence – indeed all of - their job. 332. Counsel concedes that one need not be a doctor to perform medical functions; however the concentration of functions exclusively under the doctors’ medical scope of practice is what takes the PAs outside the ambit of the word “paramedical”. 333. In counsel's submission, the OLRB cases pertaining to “paramedical” employees are simply irrelevant, for present purposes, because they all deal with “paramedical” employees of one kind or another - not “medical” employees - and none of them deal with physicians’ assistants. 334. There is no OLRB decision pertaining to PAs; nor (the Hospital argues) would the PAs fit very well in the paramedical collective agreement, when the existence and nature of their work is tied so closely to what the doctor (a non-employee) does. In a layoff for example, they would have no place to go, without finding some other doctor to “take them on”. That is quite different from the paramedical employees, whose job security is not tied to th eir consensual relationship with a single individual who is not a Hospital employee. 335. In the result, the Hospital submits that while the handful of Physician Assistants could have their own separate bargaining unit; they do not fall into the existing “paramedical” bargaining unit, because they are not “paramedical” employees. 91 336. The Union’s grievance should therefore be dismissed. 337. The Employer referred to a number of cases, which, like the Union’s case references, have been collected in Appendix A to this Award. XII – Discussion: what the task of “interpretation” entails 338. This case involves the interpretation/application of a particular word in a collective agreement - the word “paramedical” - and I am grateful for the thorough and thoughtful submissions of counsel. However I do not think that it is necessary to engage in a review of the “legal rules” for interpretation of “contractual documents”. That case law was not the main focus of the parties’ arguments and I do not think that it is necessary to review those cases here.8 339. That said the Labour Relations Act requires that a collective agreement be “in writing”, so it is trite law that the parties’ obligations are to be determined by the “words” in their collective agreement and that those words should be given their ordinary meaning (i.e. their dictionary meaning) unless there are good reasons to do otherwise. 340. It is further understood that words can take their meaning from the setting in which they are found and from the purpose for which they were chosen (here to define a particular kind of “bargaining unit”); and that those “contextual factors” can be used as an aid to interpretation: to suggest a broad or narrow or specialized meaning for the word(s) in question; to help make a choice between competing reasonable interpretations; or to help resolve disputes about how a particular word should be applied in particular (often unforeseen) circumstances. 8 See however, arbitration cases such as Communications Energy and Paper-workers’ Union, Local 777 and Imperial Oil Strathcona (Policy Grievance) (2004) 130 L.A.C (4th) 239 and Court cases such as Eli Lilly & Co. v. Novopharm Ltd., [1998] 2 S.C.R. 129, Re Viterra and Grain Services Union an Arbitration Board chaired by William Hood (2011), SKQB 439, Dumbrell v. Regional Group of Companies Inc., [2007] ONCA 59 (CanLII) and Salah v. Timothy’s Coffees [2010] ONCA 673 (CanLII). 92 341. It may also be useful to consider whether a proposed interpretation leads to clearly unanticipated or anomalous results (whether or not they rise to the level of an “absurdity”); because an adjudicator should not lightly choose a meaning that produces such untoward consequences if there is a reasonable alternative interpretation that avoids that outcome. 342. Finally, since the critical word in this case (the word “paramedical”) is derived from OLRB practice and parlance, I think that it may be useful to consider where that bargaining unit terminology “comes from” and what it was meant to achieve – the general legal landscape, so to speak. Because I agree with the Union that the word “paramedical” in Article 1.02 has been plucked from a particular legal setting, where it is customarily used to describe a particular kind of “bargaining unit”; so I think that it may be helpful to understand what a “bargaining unit” is and what that “paramedical” terminology customarily refers to – not least because it was the OLRB that had a hand in confirming the “paramedical” bargaining unit at the Ottawa Hospital. 343. I will begin with that general legal landscape. 344. I will then turn to the disputed word itself, the way in which the parties have used it in their Collective Agreement, and whether the “work distinctions” asserted by the Employer (“medical” duties versus “paramedical” duties) command the result that the Hospital proposes. XIII – The general legal landscape: what is a “bargaining unit”? 345. In the instant case, the word "paramedical" is the lynch-pin that anchors the “bargaining unit” definition found in Article 1.02. It is a word that describes the essence or quintessential nature of that bargaining unit; and from this perspective, it distinguishes those 93 kinds of employees, in that kind of bargaining unit, from other kinds of employees, in other kinds of bargaining units (like the specialized bargaining unit for “nurses”). 346. But what is a “bargaining unit” and how is it established? 347. “Bargaining units” are the basic building blocks for collective bargaining within an employer’s organization and they are typically established by the OLRB when a union applies for “certification” as the “bargaining agent” for a group of unrepresented employees. Those employees do not have unlimited freedom of association. Nor is it open to the union to represent only its members or supporters. Instead, under the Labour Relations Act (“OLRA”) the employees have to be grouped together, for bargaining purposes, into “appropriate bargaining units”. And by and large, it is the OLRB that determines what is “appropriate”. 348. The “bargaining unit” identifies the employee-grouping within which the union must establish majority support; and if the union is successful in that regard, then that bargaining unit becomes the grouping of employees for whom the union negotiates with a view to concluding a collective agreement. It is also the group of employees to whom any resulting collective agreement will (normally) apply. 9 349. The term “bargaining unit” is defined in the Labour Relations Act as “a unit of employees appropriate for collective bargaining, whether it is an employer unit or a plant unit or a subdivision of either of them”. However, the OLRA does not give the OLRB much guidance on how such bargaining units should be constructed - other than noting the possibility of a "craft bargaining unit" (plumbers, electricians and the like, mostly in the construction industry) and 9 Section 45 of the OLRA requires that ever y collective agreement specify the bargaining unit of employees who are covered by that agreement – which is done here in Article 1.02. 94 granting “professional engineers” (but only that “profession”) a right to have their own bargaining unit, unless they want to be mixed in with other workers. But apart from that, the OLRB can fashion whatever employee “bargaining unit” it considers “appropriate” in the circumstances. It is a policy decision that the Legislature has left to the OLRB. 350. These bargaining units (once established) can later be modified by the bargaining parties or by the OLRB under the Labour Relations Act or the Public Service Labour Relations Transitions Act – usually, if the employer organization changes in some way (like a merger with some other employer). However, the OLRB’s determination is the important starting point; and any later evolution will likely be influenced by that history – hence the persistence of a “paramedical” bargaining unit at Ottawa Hospital despite many organizational changes over the years and a number of rounds of collective bargaining. 351. The policy considerations that underlie these bargaining unit determinations are explored in a number of OLRB decisions that were referred to by the Union in argument. 10 I will touch on them only peripherally here. However at the risk of being unnecessarily obvious I should note that fixing the number or identity of employees in the “bargaining unit” at the time of certification does not mean that the union's “bargaining rights” are tied to those particular individuals. The union’s “bargaining rights” pertain to the “bargaining unit” defined by the 10 Re Stratford General Hospital and Ontario Public Service Employees and Allied Health Professionals et al [1976] OLRB Rep. September 459; and Canadian Union of Public Employees v. Hospital for Sick Children , 1985 CanLII 899 (ON LRB), which discusses International Brotherhood of Electrical Workers Local Union 1687 v. Kidd Creek Mines Ltd., 1986 CanLII 1511 (ON LRB) 95 OLRB (and later by the collective agreement); so that any subsequent enlargement or contraction of the workforce does not affect the “scope” of those bargaining rights. 11 352. In the result, any new employee who fits into the bargaining unit description will automatically be covered by the collective agreement upon being hired - regardless of what his/her individual wishes may be, and regardless of the employer’s wish to deal with such employees individually. It is sufficient if the newcomer meets the bargaining unit definition; and if s/he does, then the recognition clause of the collective agreement (here Article 1.02) automatically brings him/her into the legal regime to which the collective agreement relates. 353. In a unionized environment, therefore, it is not open to the employer to bargain with, or enter into an agreement with, an employee that is inconsistent with the terms of the collective agreement. The new employee takes the collective bargaining framework as s/he finds it and so must the Employer. For as the Supreme Court of Canada observed in Syndicat Catholique des Employés de Magasins de Québec Inc. v. Paquet Ltée, [1959] SCR 206, 1959 CanLII 51 (SCC), once a trade union is on the scene and a collective agreement is in place: There is no room left for private negotiation between employer and employee. Certainly to the extent of the matters covered by the collective agreement, freedom of contract between master and individual servant is abrogated. The collective agreement tells the employer on what terms he must in the future conduct his master and servant relations. 354. This is also a reminder, I think, that one has to be cautious about the evidentiary weight to be given to individually agreed-upon terms of employment, that are different from those that have been negotiated collectively and appear in a collective agreement. Such terms 11 See the comments of Laskin CJC in Beverage Dispensers & Culinary Workers Union, Local 835 v. Terra Nova Motor Inn Ltd., [1975] 2 S.C.R. 749). 96 may not help to establish the meaning of the “recognition clause”, they may only provide evidence of its breach; moreover, it would hardly be surprising if employees outside a bargaining unit had fewer or different “rights” than those within it. These differences may not tell us much about whether the newcomers should have been part of the bargaining unit in the first place. 355. A bargaining unit can cover either all employees of the employer or some subdivision of them; but I think that it is important not to overemphasize the extent to which a “bargaining unit” is “about work”, as such, except at a high level of generality. Because there are lots of bargaining units that encompasses “all employees” of an employer without any other work qualification at all, or (as in the instant case), there are units that cover hundreds of employees in different occupations, with very different salaries and work responsibilities. 356. What matters is an affinity for bargaining purposes – an affinity that the OLRB has said can be established by common employment alone; 12 and, it is also important to appreciate that drawing these bargaining unit lines (and thus the eligibility to participate in collective bargaining), is distinct from the outcome of that process. 357. Once these bargaining unit determinations have been made, they establish the “structure” of collective bargaining within each employer’s organization (i.e. the number of bargaining units and thus the potential number of unions); and there is no doubt that such units can sometimes be related, at least in a general way, to the mix of jobs or the kind of work that 12 In Terra Nova Laskin CJC observed: “Conceivably, there may be no work categories, but only a specification of “all employees of an employer”, excluding those in a managerial capacity who may not be included in a bargaining unit”; and in Metroland Printing, Publishing and Distributing Ltd. vs. Communications Energy and Paper Workers et al [2003] OLRB Rep Jan/Feb 104 the OLRB noted that “It is now common for employees with quite different terms and conditions of employment and different employment aspiration s, including part-time and full-time and temporary employees, to be placed in one bargaining unit.” 97 employees are engaged in. However the connection may also be quite general or attenuated; and in fact, collective bargaining practice actually demonstrates considerable diversity.13 358. It must also be remembered that collective bargaining is, by definition, about groups - not about individuals or their particular duties; so it not unusual for a bargaining unit to encompass different kinds of employees, doing different kinds of work and earning quite different wages – like the paramedical bargaining unit in the instant case (see paragraph 2 above). Similar work is not a prerequisite for inclusion in a bargaining unit – although a very large work force may well be subdivided, for bargaining purposes, as in the instant case. 359. The cases referred to in footnote 10 emphasize that the OLRB’s role in bargaining unit determination is a policy-laden one in which the Board is balancing the right of employees to organize themselves for collective bargaining purposes, on the one hand, and the need for a sensible “bargaining structure” on the other – including the avoidance of too many bargaining units (“fragmentation”) and the utility of standardized units.14 And obviously, the fewer bargaining units there are in an employer’s enterprise, the simpler the collective bargaining process is likely to be, and the less likely there will be disputes about work allocation as between employees in different bargaining units represented by different unions. More bargaining units means more bargaining and more bargaining complexity. 13 The OLRB discussed that diversity in the Hospital for Sick Children case at paragraph 14; and see generally: Sack & Mitchell Ontario Labour Relations Board Practice, which also discusses hospital bargaining units. 14 Such standardization can simplify organizing, can make bargaining go more smoothly, and can facilitate comparison with other employers – something that is especially useful in the hospital sector, where there is “multi - employer pattern bargaining” and the compulsory arbitration process under the Hospital Disputes Arbitration Act prompts arbitrators to look for comparisons in similar bargaining units in other hospitals. As to the value of comprehensiveness, see: Service Employees International Union, Local 2 04 v Humber/Northwestern/York-Finch Hospital, 1997 CanLII 15494 (ON LRB) 98 360. However, when the OLRB is building bargaining units, it does not normally create a bargaining unit that is confined to a single job classification, employee type, or department, unless it is obliged to do so by the “craft unit” provisions of the OLRA (section 9(3)). 361. For example, in Kid Creek Mines supra the Board refused to permit a stand-alone bargaining unit of 106 licensed electricians who worked in an industrial enterprise with hundreds of other employees - even though those electricians were highly skilled individuals, who had an identifiable “trade” and statutory accreditation, and they made up a self-contained group, that was distinguishable from other industrial workers. These employees did not meet the (historically limited) “craft unit” definition in the OLRA, and in the OLRB’s opinion, they did not constitute an “appropriate” unit for bargaining purposes. The OLRB was not persuaded that an isolated island of collective bargaining made collective bargaining sense. 362. The OLRB has not been inclined to endorse this kind of “balkanization” of the work force – an aversion to “fragmentation” which the OLRB also applies in other labour relations settings, including in hospitals, where similar concerns about “fragmentation” arise. 15 363. For example, in Service Employees International Union, Local 204 v Humber/Northwestern/York-Finch Hospital, [1997] CanLII 15494 (ON LRB) (which involved a proposed revision of the bargaining unit after a merger) the OLRB was unwilling to sever off the skilled trades’ personnel from the other emplo yees in the “standard” hospital “service bargaining 15 For historical reasons, hospital nurses (who organized very early), have acquired a right to what amounts to a “craft bargaining unit”; but by and large that approach has not been extended to other professional groups in public hospitals. In Hospital for Sick Children, supra, the OLRB noted that the nurses-only bargaining unit was “based firmly on established collective bargaining practice, and whatever its merits, viewed with the benefit of hindsight, it is a claim that cannot now be denied” – a form of words that suggests that were it not for that history, the nurses might be included in the paramedical bargaining unit along with other health care professionals. Because other well defined groups like Pharmacists or Registered Psychologists do not have their own units, they are in the open -ended “paramedical unit”. 99 unit”, even though these skilled tradesmen were a distinct group. For of course, if every “specialized” hospital work group had its own “bargaining unit”, then there could be dozens of bargaining units, each potentially represented by a different trade union or employee association. The hospital’s collective bargaining structure would look like a checkerboard. 364. On the other hand, if the parties agree on the bargaining unit description, the OLRB may well accept their agreement. The strong preference for standardization and comprehensiveness may yield to the parties’ local agreement; or tailored to pre-existing bargaining rights that cannot be easily over-ridden ex post facto when a new union comes on the scene. 16 New collective bargaining formations are built upon or made to conform to, what is already there; and that status quo may have to be taken into account, to some extent, even when organizations change in a way that triggers the OLRA or the PSLRTA. 365. Once the bargaining unit is established by the OLRB, collective bargaining proceeds on that basis, more or less permanently, unless the parties agree to modify the bargaining unit description or the OLRB later does so under the OLRA or the PSLRTA. However, the parties cannot be forced to make such modifications to the bargaining unit definition; so that this bargaining unit status quo tends to persist over the years and over successive rounds of bargaining – as in the instant case, where a “paramedical” bargaining unit has been part of the collective bargaining picture for many years. 366. Finally, I should note that when the OLRB constructs a bargaining unit of employees under the OLRA, it cannot include in that bargaining unit persons whom the statute 16 See: OPSEU v. Ottawa General Hospital [1982 OLRB Rep. Dec. 1867 and [1983] OLRB Rep March 434; and the 1993 Riverside Hospital decision at Volume 5 tab 3 of the Union’s materials; and see Re Ottawa Hospital et. al. [2005] OLRD No. 380, where the Board confirms its preference for comprehensive bargaining units, but notes that it also has to take into account what is already there (which is easier if the status quo reflects standard units and more difficult if it does not). 100 itself excludes from collective bargaining by deeming them not to be “employees” to whom the statute applies. Those “exclusions” are set out in section 1(3) of the OLRA, and they include: “managerial” personnel; persons employed in a confidential labour relations capacity; and an odd collection of “professionals”: “members of the architectural, dental, land surveying, legal or medical professions entitled to practice in Ontario and employed in a professional capacity". 367. No such legal barrier applies to other kinds of “professionals” - who are entitled to bargaining collectively in whatever “bargaining unit” the OLRB finds to be appropriate. There is no special statutor y treatment for “professionals”, as such, (except for engineers), nor is there any statutory prescription for might constitute a “profession”. 368. However since the groups mentioned in section 1(3) of the OLRA are not “employees” under the OLRA then (prima facie at least) none of them can be part of a “bargaining unit” or participate in collective bargaining under the OLRA. That means that medical doctors – true “medical professionals” – members of the “medical profession” (and the College Physicians and Surgeons) - are excluded from bargaining under the OLRA by virtue of section 1(3) of the Act, even if they are “employees” for other purposes. 369. To be sure, persons who are not “employees” under the OLRA may still be able to form themselves into groups and engage voluntary bargaining with their employer; and the results of such discussions may produce a document that resembles a “collective agreement”. Collective bargaining is a tool that is not confined to persons covered by the OLRA. But OLRA “bargaining units” are, by definition, composed of “employees” under the OLRA; and so are the mechanisms for dispute resolution that are prescribed in the OLRA. 101 XIV - Where does the “paramedical” bargaining unit terminology come from, and what does hospital industry practice tell us about the composition of such “paramedical” units? 370. Bargaining units are determined on an employer by employer basis; and there is no dispute that the OLRB’s preference in public hospitals is for large “generic” bargaining units, like the ones found at the Ottawa Hospital. Those hospital units normally include: a “service unit” of largely blue collar workers (porters, cleaners, food service personnel and building maintenance staff); an “office & clerical” unit covering the hospital’s administrative personnel; a nurses’ unit; and a “paramedical bargaining unit of auxiliary health caregivers, doing professional, technical and diagnostic support. Taken together, these units cover virtually all of the hospital employees who are eligible to bargain collectively under the OLRA. 17 371. This pattern of generic bargaining units grew out of the OLRB’s experience in the 1960’s and 1970’s when unionization spread into public hospitals and the Board had to consider what the bargaining unit(s) “should look like” in these large public sector institutions, which employed a novel mixture of unskilled, but also quite highly skilled professional and technical employees. What was the appropriate grouping of such employees for collective bargaining purposes? Should they all bargain together? Or should there be subdivisions? And if so, how many bargaining units should there be, and of what kind? 372. Insofar as the “paramedical bargaining unit” is concerned, the leading case dealing with these issues is Stratford General Hospital, supra, where the OLRB was presented with competing proposals for how “technical” and “professional” employees should be grouped 17 See generally Sack & Mitchell Ontario Labour Relations Board Practice Chapter 3 paragraph 3.326 ff. At the Ottawa Hospital the “service” and “office/clerical” bargaining units have been combined into an even bigger and more comprehensive bargaining grouping. 102 together for bargaining purposes – an argument that was being advanced, in that case, by two different unions that were trying to organize two different (and overlapping) configurations of hospital employees. It was an ideal setting in which to address the normative question of what the bargaining structure for hospital employees “should” look like; and, as it turned out, the OLRB made a policy decision that ultimately set the pattern for the hospital sector as a whole. 373. In Stratford General Hospital the Board began its analysis by reviewing the employment characteristics of the employees found in a large public hospital. These factors included: the variety, diversity and “professionalization” of this skilled work force; the purported distinctions between “professional” and “technical” employees; the importance of post- secondary educational requirements as a prerequisite for their jobs; the many specialized “silos” in which these employees worked; the way in which these pockets of employees with specialized expertise interacted with other employees and with doctors; the effect of statutory recognition, registration or certification for particular groupings (like pharmacists); the existence of outside professional associations that reflected the employees’ “professional interests” regardless of where their members might be working from time to time; and so on. 374. It was unique setting – albeit one in which employment issues like wages and benefits had to be sorted out, just like for any other large public sector employer. Because municipalities and large public sector organizations like Ontario Hydro or the Ontario Civil Service also employ large and diverse collections of employees – including some highly trained technical employees and professionals. 375. In Stratford General Hospital the Board examined the duties and responsibilities of the employees whom the two unions sought to organize, then it turned its attention to what the 103 “appropriate” bargaining unit(s) “should be” for this diverse group of skilled or well-educated employees, who had expressed an appetite for collective bargaining by joining the two unions. How should they be grouped or subdivided for collective bargaining purposes? Should “technical” employees be separated from “professional” employees; and if so, what was a “profession” and how should such lines be drawn? Should each definable “profession”, department, specialty, or subgroup have its own bargaining unit? Or should all of these knowledge workers be put into one big bargaining unit – treating them all together, for collective bargaining purposes, and leaving it to collective bargaining itself to sort out what their different work responsibilities might mean for wages or other terms of employment? 376. Those were the issues that were explored in Stratford General Hospital; and ultimately, the OLRB concluded that all of these professional and technical employees should be grouped together, for collective bargaining purposes, into a single, large, so-called “paramedical” bargaining unit. 377. In Hospital for Sick Children supra (issued in 1986) the OLRB summarized the result of the Stratford General Hospital case, this way: Some of the same concerns [about fragmentation] underlie the Board's analysis in Stratford General Hospital, [1976] OLRB Rep. Sept. 459, which involved an attempt by two unions to organize differently described but overlapping units of paramedical employees. The initial problem was the description of the appropriate bargaining unit. The Board recognized that in the special environment of a public hospital pharmacists, physiotherapists, social workers, etc. all had an arguably distinct identity stemming from such factors as their specialized training, outside professional or quasi-professional associations, and particular departmental focus. In this sense, each sub-group and each department could claim a distinct community of interest. However, the Board made it clear that this did not mean that each of these groupings would constitute a separate bargaining unit for collective bargaining purposes. Such balkanization of bargaining would create serious administrative problems for the Hospital. Nor, for reasons set out at length, was the Board 104 persuaded that technical, paramedical, paraprofessional and professional employees could, or should, be distinguished for collective bargaining purposes, even though there were obviously important distinctions between the various sub-groupings based upon their level of education, responsibilities, degree of independence, and how far they had travelled on the "road to professionalization". The Board was of the view that for collective bargaining purposes, they could all comfortably co-exist within one paramedical bargaining unit. 378. The essence of the OLRB’s views can be seen in the following passage toward the end of the Stratford General Hospital decision, where then Vice Chair G.W. Adams, summarized the central characteristics of the “paramedical” bargaining unit in a passage that reads much like the analysis in the Calgary Regional Health Authority case, twenty years later: We think Friedson’s observations [a discussion of the occupations that cluster around the work of healing which is ultimately controlled by a doctor] capture some of the most salient characteristics shared by the occupations affected by this application. The evidence clearly demonstrates that all the occupations are organized around the medical profession, and despite the ethical stance taken b y some of the witnesses, we are satisfied that all of the occupations are subordinate to that profession. They perform their work at the request of a doctor and the work to a greater or lesser extent is monitored by a doctor. In fact, the similar regulatory treatment proposed for each of the occupations by the Committee on the Healing Arts suggests that Committee shared our opinion with respect to these common characteristics. The Board is also satisfied that all occupations are integrally related to the treatment process and while there may not be significant direct contact between all the occupations in the two groupings proposed by AAHP, all of the occupations sought to be represented by AAHP rely upon information and analysis provided by many of the other occupations and must be fully familiar with the significance of their activities. Therefore, in this sense there exists a functional interdependence between the activities of the two groups of occupations…These common characteristics aside, the Board’s aversion to fragmentation or preference for a more comprehensive bargaining unit cannot be ignored….Thus even if the units proposed by AAHP were considered appropriate, the Board could exercise a discretion in favour of the more comprehensive bargaining unit proposed by OPSEU. 105 379. That is how the word “paramedical” came to be attached to the kind of broad, generic, bargaining unit that has become the norm in public hospitals and that is described in the Ottawa Hospital Collective Agreement at Article 1.02. 380. Why did it become the norm? Because when the OLRB was constructing bargaining units in later hospital cases, it applied the same holistic approach enunciated in Stratford General Hospital - resisting specific exclusions of one kind or another, and opting instead for a single large bargaining unit, that captured the full range of occupations “organized around the medical profession” and “subordinate to that profession” (as the OLRB had put it in Stratford General Hospital). Moreover, the OLRB maintained that holistic view, regardless of the actual mix of such occupations or “professions” in the particular institution under review. 381. For example: in Ontario Public Service Employees Union v. Hôpital Montfort et al Respondent [1980] O.L.R.B. Rep. 1647 the Board included pharmacists, physiotherapists, dieticians, social workers and psychologists in the same paramedical bargaining unit, even though it was argued that they had a different community of interest from other employees in other occupational groups. Similarly, in S.E.I.U., Local 204 v. Toronto East General & Orthopaedic Hospital Inc., [1981] O.L.R.B. Rep. 1672 the OLRB said the same thing to the pharmacists who wanted to be excluded from the paramedical bargaining unit, on the basis that they were a distinct profession with their own unique interests. Likewise in OPSEU v. Windsor Western Hospital [1979] OLRB Rep. May 462, the Board refused to exclude psychologists and psychometrists from the paramedical bargaining unit. And in Allied Health Professionals v. Queensway General Hospital et al. 1996 OLRD No. 44, the Board refused to exclude employees in the positions of speech-language pathologist, dietitian, chiropodist and pharmacist (again). 106 382. In each of these cases the OLRB ruled that the disputed individuals were “paramedical” employees, who were properly part of the “paramedical” bargaining unit, for collective bargaining purposes. They were in occupations “organized around the medical profession” and “subordinate to that profession”; and, as such, for collective bargaining and labour law purposes, they should all be in the same “bargaining unit” – the “paramedical” bargaining unit - even though they did very different work or were in separate “professions”, or had different work hierarchies for regulatory or other purposes, and no doubt they earned different salaries, commensurate with their particular skills and abilities. 383. That was all true. The employees in question were very different. But for bargaining unit purposes they were all “paramedical employees”, despite their different educational background or professional role in the workplace - and whether or not they were involved in direct patient care, or ancillary functions associated with diagnosis and treatment (all under the ultimate authority of doctors, who had their own specialties and subdivisions while remaining members of the “medical profession”). 384. I do not think that it is necessary to burden these reasons with further examples of the way in which the OLRB has approached the determination of bargaining units in public hospitals, or the way in which the OLRB has prescribed, and described, the composition of particular “paramedical” bargaining units (i.e. the kinds of employees whom the Board thought “should” be embraced by the word “paramedical”). I am not the OLRB. 385. The point is: for collective bargaining and bargaining unit purposes, the OLRB has ignored the work distinctions between and within these technical and professional employee groups; and it has, instead, put them all together, for bargaining purposes, into a single, 107 comprehensive “paramedical” bargaining unit, that embraces all employees and occupations that are “organized around the medical profession” and “subordinate to that profession”. 386. It is an elastic envelope (and descriptive word) that includes employees of many types and at all levels, with (in the present case) those at the top of the pyramid earning three times as much as those at the bottom of the scale. But they are all part of the same “paramedical” bargaining unit - a “collectivity” for bargaining purposes. 387. They are all paramedical employees - leaving it to bargaining itself to sort out what wages should be attached at particular levels of attainment and what common protections should be applicable to everyone. And leaving it for the parties or the regulators to sort out what credentials might be required for particular jobs or how someone progresses through the ranks of each professional grouping. 388. That is what the umbrella-word “paramedical” means when it is used by the OLRB in relation to hospital bargaining units; and that it is how the OLRB applies that word when it creates or modifies such “paramedical” bargaining units. And as the Union points out: that is how some other labour tribunals have defined the term “paramedical” as well (see again: Calgary Regional Health Authority supra). 389. Accordingly it seems to me that when the parties adopt or continue that very same language in their collective agreement, then there is at least an inference that it carries the same generalized, catch-all, holistic meaning that its originator and creator (the OLRB) had, unless the parties choose to bargain something else, or add specific exclusions or exceptions (writing their own dictionary so to speak). 108 390. In this respect the “recognition clause” is a little different from some of the other clauses in collective agreements that are hammered out only between the parties themselves. Because it reflects the OLRB’s handiwork and terminology, which, once adopted (or more commonly imposed by operation of law), forms the basis for future collective bargaining unless the parties themselves negotiate specific modifications. And it exists separately and apart from the collective agreement in which it is embodied from time to time. 391. So what does all of this “general background” mean for the rather narrow interpretation problem that arises in this case? Only this, that it tends to support the simple and straightforward narrative advanced by the Union; namely that:  hospital employees, including “professional” employees, (but excluding doctors), are entitled to engage in collective bargaining under the OLRA and do, in fact, engage in such collective bargaining  there are large generic bargaining units for such hospital employees that are normally created by the OLRB; and one of them is the so-called “paramedical” bargaining unit, which covers professionals and knowledge workers of many kinds and categories  that paramedical bargaining unit is necessarily open-ended and diverse, so as to capture a broad grouping of such employees, even though there are many different jobs and job hierarchies within that group, and the employees perform quite different work functions  labour relations policy (as expressed by the OLRB) supports such comprehensive bargaining units and discourages exclusions or potential fragmentation into disparate islands of collective bargaining, even where technical or professional employees have their own unique interests  so that when a new “professional” scientifically-trained group of employees comes on the scene, it is sensible to ask whether they fit somewhere in the existing framework – particularly when the “paramedical” bargaining unit is clearly intended by the OLRB to be highly “inclusive” and to avoid islands of collective bargaining, and to encompasses a diverse grouping of professional and paraprofessional employees, whatever their particular specialties may be. 109 392. That is why the Union submits that its proposed interpretation best accords with the generally understood meaning of the word “paramedical” - a “term of art”, so to speak, that originated with the OLRB and should be given liberal interpretation, as the OLRB has given it. 393. For, as the Union sees it, when the bargaining parties adopt or maintain this “paramedical” terminology in their bargaining unit description, they should be taken to have adopted its “collective bargaining meaning” as well - which is: it applies to persons employed in occupations (including educated health professionals), who are subordinate to, and organized around, and “under” the medical profession. In the Union’s view, that describes the PAs. * 394. I agree with the Union that this background supports the Union’s proposed interpretation of the word “paramedical”. However, that is not the only thing that does. So let me now turn to the more conventional approach to interpretation: (1) the “plain meaning” of the word in dispute; and (2) whatever enlightenment can be gleaned from the linguistic and operational context in which the disputed word is found. XV – What is the ordinary meaning of the word “paramedical”? 395. “Contract interpretation” is conducted in accordance with some general legal principles but the raw materials for that exercise are the words that appear in the parties’ collective agreement; moreover, no one suggests that a labour adjudicator should read those words "like a Martian with a dictionary", because the context and purpose can matter too. However, the “ordinary meaning” of a word is a useful starting point for analysis, and it seems to me that the place to look for the ordinary meaning of a word is in a dictionary. 110 396. “Medicine” concerns the diagnosis, treatment and prevention of disease and the adjective “medical” is a descriptor that relates to the science or practice of medicine. It also relates to an established profession (“physicians”) that is distinct from other “health care professions” (like “nurses”). And as I have noted above: doctors – the true “medical professionals” - are excluded from “collective bargaining” under the Labour Relations Act, even if they are “employees” working for an “employer” to whom that statute otherwise applies. 397. However, the fact that physicians form a distinct profession that is excluded from collective bargaining under the OLRA, does not mean that their work functions cannot overlap with, or be shared with, other health care providers (like nurses or nurse practitioners or “paramedical” employees) to whom the OLRA does apply; or that, for example, psychiatrists and psychologists cannot work together for the benefit of a patient, even though their training and accreditation are different. In today’s world, medical doctors do not have a monopoly on the delivery of “health care” or “treatment” - although a medical doctor’s authorization may be required before particular “medical” acts can be done or delegated, or before particular kinds of diagnostic tests or treatments can be initiated. 398. In the result, the “work” that doctors once did (or “treatment” more generally) may no longer be exclusively done by a doctor; so that, these days, it may be more difficult to distinguish between “medical” functions and “paramedical” functions on a basis that is unrelated to the professional status or accreditation of the person who is doing those functions (let alone to conclude that such differences should “matter” for collective bargaining purposes). The “health care team” is far more diverse than it once was, and so is the distribution of patient responsibilities, the means of delivering different kinds of “treatment” and the professions 111 associated with those roles (like midwives or the “nurse practitioners” described in some of the cases referred to by the Union, or the new “PA” or the new “Anaesthesiology Assistant”). 399. It seems to me that these developments tend to muddy the distinction (if there is any for collective bargaining purposes) between what “doctors do” and what other hospital care- givers do; and between “medical” services on the one hand and “paramedical” services on the other – a distinction that lies at the heart of the Employer’s argument, to which I will return later. 400. In any event, the disputed word in this case is “para-medical”, not “medical”; so what does the addition of that prefix, “para”, add to the base word “medical, and what does that combined word, “paramedical”, then mean - where, as here, it is being used as an adjective and an anchor word to identify a grouping of employees for collective bargaining purposes? 401. The prefix "para" is of Greek derivation and has come to identify objects or activities that are auxiliary to, or derivative of, or alongside of, those denoted by the “base word” to which that prefix is attached. Thus, in English, the prefix "para" is often used in the “naming of occupational roles considered ancillary or subsidiary to roles requiring more training or of a higher status, on such models as paramedical and paraprofessional” (to borrow the words of the on-line source, Dictionary.com). For example, within my own profession one now finds “paralegals” who do “work” which might, at one time, have been exclusively done by lawyers. 402. These legal newcomers are not “lawyers”, even though they do “legal things” or may substitute for lawyers in various settings; while, by the same token, the fact that they do legal things that a full-fledged lawyer might otherwise do, is what makes them PARA-legal workers in the first place. They do not become “lawyers” by taking on more “legal work” or by concentrating exclusively on “legal functions”. They do that by obtaining the higher level 112 training and certification that is required to occupy that higher professional plateau; and until they do, they remain PARA-legal personnel, however much “legal work” they do. 403. This kind of subdivision, specialization, and stratification of labour is a relatively recent phenomenon for the “legal profession” in Ontario, but it has long been evident in the medical field and it is reflected in the following definitions of the word “paramedical”, drawn from various dictionaries (some emphasis added):  Paramedical personnel: healthcare workers who are not physicians or nurses. These include medical technicians, emergency medical technicians, and physicians assistants SEE Allied Health Professional [Tabers Encyclopedic Medical Dictionary]  Paramedical – of or relating to services and professions that supplement and support medical work but do not require a fully qualified physician (such as nursing, radiography, emergency first aid, physical therapy, and dietetics).  Paramedical: supplementing the work of medical personnel in related fields: social work; physical, occupational and speech therapy  Paramedical – connected with the science or practice of medicine; adjunctive to the practice of medicine in the maintenance or restoration of health and normal functioning [Miller-Keane Encyclopedia and Dictionary of Medicine, Nursing and Allied Health]  Paramedical – related to the medical profession in an adjunctive capacity, for example denoting allied health fields such as physical therapy or speech therapy [Farlex Partner Medical Dictionary 2012]  Paramedical – having a relation to the practice of medicine in a secondary or supplementary role, as physical therapy  Paramedical – a person trained to assist medical professionals and to give emergency medical treatment [Farlex again – my emphasis]  adjective, paramedical – denoting a person who assists physicians and nurses in their activities (my emphasis)  Paraprofessional – a trained worker who is not a member of a profession but who assists professionals (my emphasis). 113 404. These dictionary definitions share a common theme, and in my view, they all tend to support the Union’s submission that the “Physicians’ Assistants” should be regarded as “paramedical” employees for collective bargaining and bargaining unit purposes. Because that is the “ordinary meaning” of the adjective “paramedical” when it is used in relation to health care workers. It pertains to people who are trained in the health sciences and who assist doctors or supplement what doctors do, in various ways, but who are not doctors themselves. 405. In ordinary usage, therefore, the word “paramedical” identifies a class of people who are not doctors but who may nevertheless provide health care, or “medical care”, or some kinds of “treatment”, or do medically-related functions in conjunction with “real doctors” - usually on the instruction, or under the supervision, of those doctors. It follows that they are “paraprofessionals” too – in this case, adjuncts to the “medical profession”. 406. They act as auxiliaries to the physicians with whom they work, and they may do the “work” of those medical professionals do, when the paramedical employee is delegated to do so - even though they are not full-fledged physicians. They are “para-medical” employees, who share work responsibilities with doctors and assist those doctors. 407. From this dictionary point of view, therefore, I think that the Physicians’ Assistants in this case can be fairly described as PARA-Medical employees: providers of medical care, or health care, or kinds of treatment, who are not full-fledged “medical doctors”. 408. The “plain” or “ordinary” meaning” of the word “paramedical” – the dictionary meaning of that word - supports the Union’s position in this case. 114 409. Now no doubt the PAs are different from the para-medical employees who work in particular job silos (just as “specialists” are different from “general practitioners” while remaining “doctors” and members of the “medical” profession). They are also different from the PhD “doctors” (non-medical “doctors”) whom one finds in the “paramedical unit” along with other health care professionals. And they are different again from the skilled technical employees whom one also finds in the “paramedical” bargaining unit. And they are different, too, from other “professionals”, like the “Librarian”, who is also a member of the “paramedical” bargaining unit, even though his/her connection to patient care is more remote. 410. However, the PAs are clearly not doctors; they do not have a doctor’s accreditation; they will never be doctors (unless they actually get an M.D. degree); and thus they are not full- fledged “medical professionals” - as doctors are, by definition (which is why they are mentioned in the OLRA in professional terms and are excluded from collective bargaining on that basis). 411. The Physicians’ Assistants are not “medical professionals” from this statutory (and collective bargaining) perspective and they are certainly not “doctors” who are members of the College of Physicians and Surgeons. Nevertheless, I think that the PAs can be quite accurately described as “paramedical employees”, even though they have not received statutory recognition as a “health profession” under Regulated Health Professions Act. And even though they do medical work, pursuant to a medical doctor’s delegation or a “Medical Directive”. Like the “Medical Directives” that facilitate the work of PARA-medical employees. 412. And the place for “paramedical” employees is the “paramedical” bargaining unit. 413. What matters here is not that the PAs may be doing “medical functions” (by delegation), or providing “medical care”, or doing ancillary “medical care”, or “treatment”, or 115 are standing in for a doctor, or even that they are “professionals”. What matters, is that they are “employees” engaged in science-based health care who are not doctors and thus can be fairly described as “paramedical” employees, for bargaining and bargaining unit purposes - regardless of their mix of duties. They are in occupations “organized around the medical profession” and “subordinate to that profession – to repeat the words of the OLRB in Stratford General Hospital, later echoed, by the Alberta Labour Board in Calgary Regional Health Authority. 414. Indeed, the fact that the word “medical” is embedded in the word “paramedical” signals, in itself, that such employees may be doing “medical things” or medical duties; and, in this respect the “para” prefix pertains to their professional status and not just work functions. 415. In my view, therefore, the ordinary meaning of the word “paramedical” supports the Union’s assertion that the disputed individuals in this case are “paramedical” employees; and so does the way in which the word “paramedical” has been used, historically and for collective bargaining purposes. It is a word that, in the labour relations world, describes a cluster of medical auxiliaries of many types and kinds, who are all assigned to the paramedical bargaining unit for collective bargaining purposes, regardless of their differences inter se or how they interact with the doctors who have the most responsible role in health care delivery. 416. The ordinary or dictionary meaning of the word paramedical, and the instrumental meaning of the term (reflecting the OLRB’s handiwork) point in the same direction and to the same conclusion: that the PA’s are “paramedical employees”. 417. Such individuals are “employees” entitled to engage in collective bargaining; they are not excluded from the Labour Relations Act like doctors (true “medical professionals”) are; they are not “nurses” or a natural part of some other “kind” of hospital bargaining unit (like the 116 broad service employees unit or the clerical/administrative employees unit that are the combined at Ottawa Hospital); and they fall within the ordinary ambit and meaning of the class called, for bargaining purposes, “paramedical”. 418. Indeed there is something to be said for Union’s submission that the PAs are quintessential “paramedical” employees – doctor-like, but not doctors. That is why the American Heritage Dictionary says that, in medicine, the use of the prefix “para” means “subsidiary, assistant, paramedical” and the Tabers Encyclopaedic Medical Dictionary’s definition of the term “paramedical” mentions them, specifically, by their actual job title: physician’s assistants. Their very closeness to the doctor, in function, without actually being one, is what makes them a classical or proto-typical “para - medical” employee. XVI – What can we learn from the structure of Article 1.02 and from the way in which the parties have used the word “paramedical” in conjunction with other words in their collective agreement? 419. Article 1.02 begins by identifying an open-ended constellation of employees – ALL “paramedical” employees – from which there are some specific exceptions. Those exceptions limit the application of the opening words of the clause, even for "employees" who might otherwise fall within the scope of those words; and in fact, these exclusionary terms might not even be necessary if the types of employees identified after the “save and except” were not (at least arguably) “paramedical” employees to begin with. 420. In this respect, the words following the “save and except” in Article 1.02 provide a clue to the meaning of the word “paramedical” – identifying the kinds of employees who might otherwise be embraced by that term, were it not for the fact that they have been excluded. 117 421. More importantly, though, these exceptions show that the drafters of the collective agreement know how to exclude employees from the broad “paramedical” umbrella if that is what they want to do; because that is what has been done in a number of specific instances. 422. For example, the “paramedical” bargaining unit (and thus the “paramedical” collective agreement) has no application to the staff in the Ottawa Hospital Research Institute (an institutional subdivision and exception) even if there are “paramedical” employees working there. Similarly it has no application to Laboratory Scientists (a class of employees), or to "biochemists" (a particular job classification) - even though their educational background, professional status, science-based training, work functions, pay, or benefits, might resemble those of the higher-end “professional” employees in the “paramedical” bargaining unit. 423. These named employees have been specifically excluded from the bargaining unit even though they might otherwise be regarded as or “look like” “paramedical” employees. 424. However there is no expressed intention to exclude “Physician Assistants” or employees like PAs; the Employer does not argue that the recently-hired “PAs” are just like the enumerated exclusions (nor would the available evidence support that finding); and while the Employer certainly does argue that the PAs are excluded from the paramedical bargaining unit, it is clear that certain other kinds of “assistants” are not so excluded (e.g. the “dental assistants” and the “pathology assistants” and the Anaesthesiology Assistant, from whom I heard evidence). 425. Accordingly if the proposition advanced by the Employer is to be accepted, then it is only because it flows from the meaning of the word “paramedical” all by itself, and not from any inference from the exclusion provisions of the Collective Agreement - which, if anything, 118 tend to reinforce the expansiveness and inclusiveness of the “all paramedical employee” language, from which a handful of specifically-identified employees have been excluded. 426. With that in mind, then, I think that it is worth looking at (1) the relationship between Article 1.02 and other provisions in the Collective Agreement and (2) how that word “paramedical” has been applied, in practice, by the parties themselves. Because both speak to the arguable application and intended elasticity of the word “paramedical”. 427. As will be seen, the pattern of words used in Article 1.02 is intentionally open- ended and inclusive (ALL paramedical employees…save and except). The format begins with that broad and inclusive generic category, which is then followed by some specific exceptions. And if there were any doubt that this bargaining unit was intended to be an all-encompassing one which expands, more or less automatically, whenever any new “paramedical” employee appears on the scene (a living tree so to speak), then that doubt is dispelled by Article 26.01 of the Collective Agreement, which contemplates that new “paramedical” classifications may be added to the bargaining unit from time to time. So does the job posting provision (Article 14) which contemplates that a new “position” may be created if the Hospital decides that it needs one. 428. There can be no dispute, therefore, that the word “paramedical” does not describe a closed category of employees or occupations (as the OLRB noted in one of a case involving Ottawa Hospital itself). Rather, the collective agreement contemplates that the “paramedical” bargaining unit can expand as institutional evolution brings in more employees, or more specialization, or a more complex division of labour – all of which can lead to the creation of a new class or kind of “paramedical” employee. It “catches” employee types that may not have been in existence many years ago when the paramedical bargaining unit was first established. 119 429. In this respect the bargaining unit is intended to be adaptable and to accommodate change – which, it will be recalled, is how the OLRB used that word as well. That is why the OLRB panel in the Ottawa Hospital case was careful to note that the fact that although it was addressing some disputed positions and putting them into the paramedical bargaining unit, it did not mean that the Board was exhaustively defining the composition of the bargaining unit. 430. From this perspective, therefore, the Union’s position and proposed outcome do not represent a farfetched or flimsy interpretation of Article 1.02. On the contrary, what has happened here can be quite plausibly characterized as an instance of precisely what Article 26.01 contemplates: a new type of “paramedical” employee has come along that did not exist before and that now has to be added to the bargaining unit, and a salary has to be established for that job on whatever basis or job evaluation method is applied to new “paramedical” employees. 431. Moreover, there is nothing in Article 26.01 that stipulates what that salary will be or where someone will be placed in the salary hierarchy – including at the very top, if the objective evidence (or the labour market) warrants a high salary to attract and keep the newcomer. Nor is there anything that suggests that the bargaining unit composition is determined by salary levels. 432. It also worth repeating that the existing “paramedical” bargaining unit already embraces a highly diverse collection of occupations with very different work responsibilities and levels of remuneration; and that some of these positions (from the job title at least) do not even look particularly “paramedical” let alone “medical” (the “life skills counselor” for example). Some of these employees are quite well paid and some of them are paid much less. Yet they are all, by definition, “paramedical employees” for bargaining and bargaining unit purposes, because the parties have put them into the “paramedical” bargaining unit. 120 433. Mere differences in work functions or responsibilities or salaries – in fact quite profound differences – do not necessarily take someone out of the bargaining unit. That is not how the bargaining unit is defined. 434. In application, therefore, the word “paramedical” is both flexible and exceptionally comprehensive; it is being used to describe a very eclectic mix of jobs; and it cannot be said that there is some common core of “medical” or “quasi-medical” work functions that are shared by all “paramedical” bargaining unit members, except at a very high level of generality. For in fact, the bargaining unit members do not share a strong and particularized “work-affinity” even though they are all members of the same “paramedical” bargaining unit (i.e. collective bargaining is the shared means by which terms of employment are attached to this diverse array of occupations, with very different work, pay and responsibilities). 435. Not to put too fine a point on it: whatever the dictionary definition of the word “paramedical” may be, and whatever the OLRB means by the word “paramedical”, the concept of “auxiliary” or “supplementary” functions has been stretched, in this workplace, a very long way indeed – including to people whose “work” (on the surface at least) d oesn't look particularly “medical” at all, and to individuals who may not do direct patient care. 436. Accordingly, the way in which the parties have actually used the word “paramedical” - in practice, and in this institution, and under this Collective Agreement - suggests a very broad and inclusive and elastic approach to that word, rather than a narrow and parsimonious one; and a strong work affinity seems to have very little role to play. 437. So why does it matter (for bargaining unit purposes) that the PAs have a different set of duties or a different role to play in the treatment process - particularly when the PAs meet 121 both the ordinary meaning of the word “paramedical”, and the customary meaning of the term “paramedical employee” when it is used in the collective bargaining process? 438. Why does it matter that an objective evaluation of their role might generate a higher pay rate than the Employer wants to pay them, or might put them (salary-wise) “above” some other employees in the bargaining unit, who do different things? 439. If “doing different work” - even very different work - is no signal that someone cannot be a member of this highly diverse “paramedical” bargaining unit then what is it that makes the newcomers so very different from a bargaining, and bargaining unit, perspective? 440. For example the Librarian probably has little in common "work-wise" with the animal care technician; his/her educational background, job horizons and pa y are likely to be quite different; and it is quite unlikely that the Librarian engages in the kind of hands-on care, “treatment” or patient involvement that so many other members of the “paramedical” bargaining unit do. Yet s/he is still a “paramedical employee” in the paramedical bargaining unit for collective bargaining purposes; and, in practical terms, she probably “fits better” in that bargaining unit of “knowledge workers” than (for example) into a “service” bargaining unit, with a large concentration of cleaners, porters, food service personnel and blue collar/manual workers, or into a unit of office and clerical personnel. Or at least the parties must have thought so, because the Librarian is “in” the paramedical unit, for bargaining purposes (and is thus a “paramedical” employee) even though his/her professional focus is that of a Librarian. 441. This shows, I think, that for collective bargaining purposes (and for bargaining unit definitional purposes) big differences in work functions or pay, simply do not matter very much 122 for the kind of bargaining unit taxonomy that is at issue in this case; and that one should be careful about giving undue analytical weight to work differences, per se. 442. Furthermore, while a strong work affinity does not seem to be a defining feature of this particular bargaining unit; to the extent that the “kind of work” does matter, I do not think that, from a bargaining/bargaining unit perspective, there actually is a huge chasm between the PAs on the one hand, and the high-end professionals who populate the upper reaches of the paramedical bargaining unit on the other – persons whose professional status is recognized under the Regulated Health Professions Act and who are actually paid more for the “treatment” that they provide, than the PAs are paid for the (alleged) pure “medical” functions that they perform. 443. In fact, it seems to me that the “job distance” between the individuals who are already in the paramedical bargaining unit is far greater, inter se, than it is between the paramedical employees who gave evidence and the “PAs”. 444. In this regard, I agree with the broad similarities that were identified by the Union in argument and were reproduced, in summary form, in its “Argument”. 445. In light of this collective bargaining reality (i.e. how the “paramedical” group is actually composed and the diverse kinds of employees who provide patient care of various kinds, and who the parties themselves have already agreed are “paramedical” employees for bargaining purposes), there is (in my view) nothing odd or jarring about reading the word “paramedical” in the way that the Union proposes (and that the dictionaries suggest it should be read and that the OLRB seems to have meant it to be read). They would not be a square peg in a round hole. 123 446. To be clear: I am not looking at “appropriateness” here in the way that the OLRB would look at it, in order create or amend a bargaining unit. Rather, I am looking at the actual composition of this bargaining unit (and comparing it with other in-house bargaining units) in order to see what “kinds” of employees were intended to be caught by that open-ended term “paramedical” – a word that, according to Article 26.01, can include newly created paramedical positions that never existed before. 447. I am looking at the real world application of the disputed term, in order to plumb the meaning and ambit of a word which originated with the OLRB, but which has been applied, in this work-place, by these parties, in the wide-ranging manner described above: to people who provide all manner of treatment and patient care, and even to those whose duties are more remote from hands-on patient care, and in so-doing earn widely divergent salaries. 448. And its seems to me that when one looks at the dictionary definitions, and at the use of the word “paramedical” as a kind of labour relations “term of art”, and at the actual composition of the paramedical bargaining unit under review in this case, and at Article 26.01, which envisages adding new job classifications - all as aids to interpretation – then the meaning ascribed to the word “paramedical” can easily encompass, and does encompass, the newcomers. They share the general characteristics summarized in Part X of this Award. XVII – Does the fact that PAs are aspiring to “professional status” tell us anything about their place in or out of that paramedical bargaining unit? 449. The evidence shows not only that the paramedical bargaining unit includes a diverse array of caregivers and auxiliaries, but also that, in practice, it has become a 124 “professional catchall” 18 for many jobs that reflect higher educational attainment or accreditation – as opposed (for example) to the kind of domestic or blue collar skills that are more commonly found in a “service” bargaining unit (cleaners, porters, food service personnel etc.) or the clerical and administrative functions performed by office employees. That is evident not only from the kinds of occupations that are included in the paramedical bargaining unit, but also from clauses like Article 25 of the Paramedical Collective Agreement which asserts that “Professional development is the hallmark of all health professionals”. 450. Accordingly, the paramedical bargaining unit is also, in practice, a health profession bargaining unit. That is why the medical “Librarian” can fit comfortably within the “paramedical” group even though his/her role is probably quite “auxiliary” and “supplementary” to the kinds of hands-on medical care that other, “purer”, “paramedical” employees provide; and that is why the paramedical unit is the home for all manner of “health care professionals”, even though their functions are different and there are different regulatory arrangements. 451. This placement “works” for the Librarian (and for collective bargaining purposes) because s/he is a “professional” employee – like the Pharmacist or the Psychologist, even though her role in the treatment process is more remote and rather different. Just like the Pharmacist and the Psychologist and the Chiropodist and the Anaesthesiology Assistant are quite different from one another, even though for collective bargaining purposes are all in the same bargaining unit. 452. Because the ostensible place for such “health care professionals” (who are not nurses) is in the “paramedical” bargaining unit. 18 Recall that under the OLRA there are no bargaining unit prescriptions for professionals, as such, except for professional engineers, and the handful of professions excluded from collective bargaining altogether. So it is up the OLRB and the bargaining parties to prescribe, and describe, the bargaining unit that such professionals inhabit. 125 453. In my view, that “professional perspective” also supports the Union’s argument that the word “paramedical” applies to the PAs; and in that regard, it is interesting to note that the PAs individual terms of employment contemplate continuing professional education - mirroring kind of concerns about professional development that are mentioned in Article 25. And as I have canvassed earlier: their actual terms of employment are not substantially different either (other than having a salary that might be higher if they were regarded as “paramedical” employees). 454. These newcomers are not service employees or clerical employees; and they are not nurses; and they are not doctors or medical students or medical residents; but to the extent that they can claim to be an emerging “professional status” and are engaged in patient treatment, then the “paramedical” unit is the place where one finds such “professional” health care employees. 455. The word “paramedical” in this work setting embraces such paramedical (non- doctor) professionals; and in this sense, the application of the word “paramedical” is illuminated by both what the disputed employee are and what they are not. They are health care professionals who are not doctors or nurses or medical residents; and they are certainly not service employees or office and clerical employees who have their own unit. XVIII How helpful is it to focus on “work” differences and the alleged distinction between “medical” functions on the one hand and “paramedical” functions on the other? 456. This case is “about” the interpretation of the recognition clause in the Paramedical Collective Agreement and the resulting inclusion (or not) of some employees in a collective bargaining mechanism for the purpose of establishing their pay and benefits. It is not about work, or work assignments, per se; nor is it about the delivery of health care as such; and in fact, the current Collective Agreement does not even have negotiated (and therefore contractually 126 fixed) job descriptions for the “paramedical employees” to whom it applies. Nor does collective bargaining deal, for the most part, with the way in which the work is ordered or organized or coordinated, so as to provide the optimal mix of health services for a patient. 457. In this collective bargaining regime, the creation, assignment and coordination of “work” remains the prerogative of the Hospital, having regard to its “management rights” and to any statutory prescriptions governing the delivery of health care19; and for that purpose, the Hospital has also developed a number of “Medical Directives” (an interesting word to apply to “paramedical employee”) that are signed off by physicians working in the area of specialization to which the directives relate, and that authorize paramedical employees to engage in various kinds of diagnostics, “interventions” and “treatment” functions. 458. These documents broaden the employees’ work role, they improve flexibility, and they remove the need for a specific doctor’s orders; moreover, there are Medical Directives applying to PAs and there are also “Medical Directives” applicable to paramedical employees. Many health professionals have their role extended by “MEDICAL” directives. 459. None of these documents is the subject of collective bargaining or union approval; and it is interesting to note that they make no distinction between “medical employees” on the one hand and “paramedical employees” on the other. On the contrary, they confirm that, in some instances, “paramedical” employees are routinely engaged in “medical” acts of one kind or another just like the PAs. There are “MEDICAL” directives for paramedical employees too. 19 To repeat: there is no indication that the various statutory rules pertaining to health care accreditation or what medical acts can be done by particular paramedical employees, were ever intended to have anything to do with collective bargaining (now a Charter protected right) or the salary rates (etc.) that employees in these jobs command. Likewise whatever may be the legal or professional rules that define what doctors can delegate to paramedical employees, they have nothing much to do with collective bargaining considerations. 127 460. In other words, the critical functional distinction (for bargaining unit purposes) proposed by the Employer – “medical duties” versus paramedical duties” - is not something that is rooted in collective bargaining practice or collective bargaining terminology or collective bargaining considerations, or the language of the actual Agreement; and it is not reflected in the operational and administrative materials prepared by the Hospital; and it is not reflected in the terms of employment either – terms that, in general format, are not substantially different from those of employees whose salary and benefits are determined by collective bargaining. 461. What these documents do show, is that many paramedical employees engage in “medical” functions even though they are in a para-medical bargaining unit; and, conversely, the way in which the Hospital actually treats the PAs (for salary and benefits purposes) does not reflect such distinction or even their relative worth. 462. It is also evident that a strong work affinity is not the “glue” that sticks the “paramedical” bargaining unit (hundreds of employees) together, except in a very general and attenuated way. That is the way in which the OLRB has used to term “paramedical”; and that is also reflected in the diverse collection of occupations found in the paramedical bargaining unit at Ottawa Hospital. But the Collective Agreement (like the OLRB) does not identify or draw any distinction between “medical” and “paramedical” work functions, nor is it necessary to do that for collective bargaining or bargaining unit purposes, or even for the operational purposes reflected in the Medical Directives which address the work that the employees do. 463. There are no words in the Collective Agreement that support the distinction that the Employer proposes (at least the Hospital did not point to any); and I am unaware of any arbitral or OLRB jurisprudence that supports that distinction either – not least because the word 128 “paramedical” has the word “medical” embedded within it and has been traditionally used cover a whole variety of persons who, while not being doctors, are engaged in facets of “medical care” or “treatment” (just as the Hospital’s “Medical” Directives envisage and permit). 464. There are no “medical” employee bargaining units (as opposed to “paramedical” ones) of which I am aware in Ontario; there is no Ontario practice of PAs having their own bargaining unit (like the nurses have); and on the contrary, paramedical bargaining units – including the one at Ottawa Hospital - cover lots of employees who perform ostensibly medical functions of one kind or another; while, by the same token, real doctors – true medical professionals – are statutorily excluded from bargaining by statute (providing a bright line test about “medical-ness” that the Legislature itself has drawn for bargaining purposes). 465. So the fact is: the “medical” versus “paramedical” distinction that is urged upon me by the Employer as the critical distinction for bargaining unit purposes, is not one that is rooted in collective bargaining parlance or practice; and it does not find support in the words found in the Collective Agreement; and it is not reflected in the operational documents which deal with how work is delimited, permitted or allocated; and it is not consistent with the ordinary or the “collective bargaining” meaning of the word “paramedical” either. 466. This not is fertile ground for the kind of proposed “work differentiations” that underlie the Employer’s argument – differentiations that, in the Employer’s submission, are so absolutely critical that they must exclude from the paramedical bargaining unit people whose actual terms of employment are not wildly different from those other Hospital employees, and who, as the Union corrected pointed out in argument, have many similarities and points of contact with other health care professionals. 129 467. It would have been effortless for the parties to have put in such “medical” category after the “save and except” words in Article 1.02, so as to carve out a class exclusion from the “all paramedical employee” group – as was done for radiation personnel, for example, or for the students. The Collective Agreement could also have excluded the PAs specifically – like the “biochemist”. And the evidence is that from time to time the parties have discussed specific exclusions and have made pragmatic decisions about inclusion or exclusion. 468. But there is no such negotiated exception for the PAs; and it seems to me that when I am asked to find a “non-negotiated exception”, based upon a distinction that is not firmly rooted in the Agreement, or in the collective bargaining environment, or even in Hospitals own terminology (as evidenced by “Medical” Directives that apply to “paramedical” employees) I should keep in mind Article 9.12 of the Collective Agreement which warns an Arbitrator that s/he is not “authorized to make any decision inconsistent with the provisions of this Agreement, or to alter modify add to or amend any part of this Agreement”. 469. In my view, this is an “orange light”, that cautions an adjudicator not to turn an exercise of “interpretation” into something that it is not – in this case to exclude from the bargaining unit a group of employees whom the parties have not expressly excluded, and who certainly appear to be “paramedical” employees when the usual tools of interpretation are brought into play. And that is especially so when the subject of “exclusions” has already been addressed, in some detail, in the Collective Agreement itself. 470. In my opinion, all of this underscores the novelty of the distinction that the Employer wishes to draw in this case: that a non-doctor health care provider (which is the ordinary, dictionary meaning of the word “paramedical”), is really a “medical employee” for 130 collective bargaining purposes, rather than being a “para-medical” one - when (to state the obvious) the word “paramedical” is the labour relations label that has been used for decades (and in this very milieu) to describe a very diverse grouping of knowledge workers who work with doctors and who deliver treatment of various kinds, but who are not doctors themselves. 471. And when (again to state the obvious), the compound-word, paramedical, has the word “medical” embedded within it, and the local operational documents in this workplace – the “Medical” Directives – make it is clear that that the paramedical employees are expected to perform “medical” functions of one kind or another (which surely indicates that they could be considered “medical employees”, too, at least in this functional sense). 472. Furthermore, I do not think that there actually is a huge difference (from a collective bargaining perspective) between the newcomers and the paramedical professionals who provide various kinds of health care, diagnostics, or treatment on the other. It is not as if the Union is trying to mix apples and oranges; and the PAs unilaterally imposed terms of employment are actually not so different from what paramedical employees bargain about either. 473. The PAs are clearly subsidiary to the physicians whom they “assist” and they certainly do different things than the other “paramedical” employees from whom I heard evidence – just as the “paramedical” witnesses’ jobs were quite different from one another. 474. But I do not think that the “role” or the “work” of the newcomers is different in kind from a collective bargaining/bargaining unit perspective; or that their terms of employment are materially different; even if it can be said that they do “medical work” (by delegation) that a doctor might otherwise do. And I certainly do not think that this takes them beyond the broad and inclusionary ambit of the word “paramedical”. 131 475. In my opinion, what is more significant, for interpretation purposes, is that the PAs fall within the dictionary definition of the word “paramedical”; they fall within the normal collective bargaining meaning of that word “paramedical” (as adopted in Stratford General Hospital 40 years ago and widely used in the collective bargaining world thereafter ); they are health care providers like so many others in the p aramedical bargaining unit; they are professional employees – also like so many others in this bargaining unit; they do medical acts or treatments, while not being doctors; and their actual terms of employment, are similar. 476. Moreover, the paramedical bargaining unit is not only open-ended and elastic, but the Collective Agreement actually contemplates precisely what has happened here: the creation of a new classification that has to be fitted into that eclectic “paramedical” unit. 477. In the result, while the distinction (“medical” versus “paramedical”) has some superficial attraction (they are different words after all) and it may find some support in the statutory regulation of work assignments or the delegation of duties, it has, in my view, no roots in the current collective agreement or in collective bargaining practice, and it is not a helpful (let alone determinative) approach for interpreting the ambit of the word “paramedical”. 478. In my view, the fact that PAs (who are not doctors) do medical duties (by delegation from doctors) or may do the same kind of work as residents, does not mean that they are not “paramedical” employees for the purposes of Article 1.02. 479. On the contrary, in my opinion, it reinforces the inference that the word “paramedical”, in this context, applies to the PAs. 132 XIX - Does the interpretation proposed by the Union produce any obvious collective bargaining anomalies or manifest labour relations mischief? 480. One of the so-called “rules” of contract interpretation is that an adjudicator should resist a proposed interpretation if it produces an absurd, obviously unforeseen, or untoward result. So is that the case here? In my view, the answer is “no”. * 481. There is no dispute that collective bargaining creates a legal envelope for the “wage-work bargain” and so does an individual “contract of employment”. However, these are merely different methods for determining the terms of employment that are attached to particular bundles of work (“jobs”); and while they are distinct from one another in a number of important ways, the actual results – salary, benefits etc. – may not look much different. That is why the PAs have individual salaries and group benefits that are similar to the bargaining unit employees – including recognition of things like the need for continuing professional development. 482. Furthermore, no one suggests that either legal envelope can conflict with any regulatory prescriptions pertaining to an employee’s work responsibilities or even that the collective agreement has much to do with the origin, description, or assignment of “work” – let alone whom the employees must obey, or please, or cooperate with, when they are doing it. 483. With that in mind (and given the flexibility of collective bargaining and access to arbitration by both parties), I do not think that the reading of the word “paramedical” urged upon me by the Union would produce incongruous or untoward results. 133 484. On the contrary, what the Union proposes would simply add (would recognize, really) another type of “paramedical” employee in what is already a very heterogeneous “paramedical” and “professional” bargaining unit - including many employees who can claim to be health care “professionals”, just like the newcomers. 485. It would be an instance of exactly what Article 26 contemplates: adding the newcomers (6 of them in this case) to a bargaining unit that already includes some 2000 other employees, many of whom are health care professionals, just like the PAs. 486. It would hardly be earthshaking, for example, if these newcomers had the kind of formalized grievance procedures that the “paramedical” staff have; or if they had the opportunity to challenge the reasonableness of managerial decisions that affect them; or if their salary were recorded in the collective agreement rather than in an individual contract of employment – even if, as one employer witness suggested, that salary might be higher if they were evaluated, objectively, and on the same basis as the “paramedical” professionals who are already in the paramedical bargaining unit and with whom the PAs sometimes work. 487. But that is not an anomaly. It only shows that there may be issues about how the newcomers should be paid in relation to others – bearing in mind that some of the paramedical employees with whom the PAs work are themselves health care professionals, and some of them are quite well paid, and some of them are quite highly educated, and some of them are statutorily recognized as a “health care profession” as the PAs are not (at least not yet). 488. Working out an appropriate salary for a new classicisation is what Article 26.01 provides for; and I do not think that the fact that the PAs might be turn out to be “underpaid” represents some incongruity, or incompatibility, even if it raises some funding issues for the 134 Hospital – issues, that, no doubt, the Hospital must grapple with for all of the employees for whom the Hospital must seek funding to pay the wage bill. 489. I appreciate the Hospital’s struggle that this regard, when politicians are long on assigning responsibilities and often short on providing the resources necessary to meet those responsibilities. 490. However, funding is an issue that applies for all programs and to all employees at the hospital; and I do not think that the interpretation issue in this case is affected, much, by the fact that the Hospital can pay the PAs less if they are excluded from that bargaining unit or it might be obliged to pay them more if they were included in it - and if they were evaluated for their actual contribution to patient care rather some fiat from the Ministry of Health. Nor does funding have much to do with the definitional question under review in this case - or that the funding challenge would be much different if the bargaining unit had 6 more employees in it. 491. Nor do I see any significant impediment to the PAs and the doctors continuing to work together as before for the good of the patients – as (on the evidence) is generally the case, for all members of the health care team, regardless of what bargaining unit they are in. 492. No doubt there may have to be some adjustments if the PAs are members of the paramedical bargaining unit; and I do not doubt that the number of PAs deployed may depend upon funding and the appetite of doctors to use them. 493. But in my opinion, there is no anomaly or absurdity or operational incongruity in interpreting the word “paramedical” as the Union urges me to do – which, in my view, is the better interpretation, for all of the reasons discussed above. 135 XX – Summary and Conclusion 494. The issue in this case is whether the word “paramedical” in Article 1.02 of the Collective Agreement applies to the recently-hired “Physician Assistants”. Having considered the evidence and representation of the parties, I find the answer to that the question is: “yes”. 495. In my opinion, the ordinary (dictionary) meaning of the word “paramedical” fairly describes these new employees and favours the Union’s proposed interpretation of Article 1.02. 496. So does the parties’ own practice of using the word “paramedical” to cover all manner of professional and technical (science-based, better educated) employees - who, in my view, are not substantially different (from a bargaining unit perspective) than the newcomers. 497. The structure of Article 1.02 also supports the Union’s position; and so does Article 26.01, which envisages the very kind of event that has happened here: the creation of a new “paramedical” classification. 498. The OLRB’s use of the word “paramedical” (imported into the Agreement) supports the same conclusion - as does the implicit policy imperative (in favour of elasticity and against fragmentation) which underlies the OLRB’s way of describing “paramedical” units. 499. The word in dispute here originated in OLRB practice; and I think that it still carries, at least to some extent, the flavour of inclusiveness and the broad policy purpose that the OLRB ascribed to it – a meaning which the parties have adopted and not blunted except by the some specific exclusions which do not pertain to the PAs. 136 500. None of the other bargaining units at the Hospital would apply to these new employees; and to the extent that they ar e an aid to interpretation, they, too, suggest that the newcomers are the “kind” of employees (scientifically trained heath care professionals) who are caught by the word “paramedical” in Article 1.02. 501. In this respect, the “paramedical employees” are identified, for bargaining unit purposes, not only by what they are, but by what they are not. 502. Conversely, I do not accept the Employer’s work-focused, proportionality argument, based upon the alleged extent of the “medical-ness” of the newcomers’ duties versus them more limited “medical-ness” (as opposed to the “para-medical-ness”) of the bargaining unit members; nor do I accept the asserted importance of that work distinction (if there really is one) for the purposes of interpreting the bargaining unit definition, Article 1.02. 503. In my opinion, the Employer’s view is not supported by the language of the Collective Agreement or by collective bargaining practice or even by the language used in the Hospital’s own “Medical” Directives; and in my view, even if the PAs relationship with the doctor is more “symbiotic” than that of bargaining unit members and they do the work of medical residents (who have their own collective bargaining procedure), I do not think this prevents them from being categorized as “paramedical employees” for bargaining unit purposes. 504. For even if it can be said that the work that the PAs do is “medical” in nature (because it is delegated to the PAs by doctors, and despite Dr. Kravicks observation that they do lots of mundane things), it is my view the word “paramedical” is the term that is used in a hospital setting to describe such non-doctors who provide ancillary “medical” care in conjunction with doctors. And in my opinion, that is what the PAs are and do. 137 505. For all of these reasons, I am satisfied that the Union has established, more probably than not, that the “Physicians’ Assistants” are “paramedical employees” within the meaning of Article 1.02 of the Collective Agreement, and this Collective Agreement therefore applies to them – and has applied to them since their date of hire. 506. I so declare. 507. In accordance with the agreement of the parties, I will confine myself to such declaration and will remain seized of any remedial issues that properly arise out of the Union’s policy grievance of March 20, 2008. Dated at Toronto this 26th day of April 2016 “R.O. MacDowell” Sole Arbitrator 138 APPENDIX A – MATERIALS FILED OR REFERRED TO IN ARGUMENT UNION MATERIALS GENERAL ARBITRAL APPROACHES Brown & Beatty Canadian Labour Arbitration: 4:2000 — INTERPRETATION OF COLLECTIVE AGREEMENTS, 4:2300 — The Collective Bargaining Context South Bruce Grey Health Centre (2006), 148 L.A.C. (4th) 442, [2006] O.L.A.A. No. 187 (QL) (Surdykowski). Huntsville District Nursing Home Inc. [2014] O.L.A.A. No. 122 (QL) (Randall). MEANING AND HISTORY OF “PARAMEDICAL” Attorney’s Dictionary of Medicine and Word Finder, v. 3, p. 45 (J.E. Schmidt). Taber’s Enyclopedic Medical Dictionary, 18th ed., p. 1408. The Report of the Hospital Inquiry Commission (the “Johnson Commission”). Manitoba Winnipeg Regional Health Authority, 2003 CarswellMan 611, [2003] M.L.B.D. No. 5, 89 C.L.R.B.R. (2d) 252. Winnipeg Regional Health Authority, Deer Lodge Centre Site [2013] M.L.B.D. No. 10 (QL). British Columbia An Inquiry Into Paramedical Professional Bargaining Units in the Health Sector [1995] B.C.L.R.B.D. No. 427 (QL). Health Labour Relations Assn. (Kelowna Hospital Society) [1977] 2 Can. LRBR 58, [1977] B.C.L.R.B.D. No. 29 (QL). Certain Ophthalmic Technicians and Health Employers Assn. of British Columbia, 2014 CarswellBC 3878, [2015] B.C.W.L.D. 1020, 252 C.L.R.B.R. (2d) 168. Alberta Alberta Labour Relations Board Information Bulletin #10: BARGAINING UNITS FOR HOSPITALS AND NURSING HOMES Calgary Regional Health Authority [1999] Alta. L.R.B.R. 458 (QL). H.S.A.A. v. Alberta (Mental Health Board), 2004 CarswellAlta 1304, [2004] Alta. L.R.B.R. 437 139 H.S.A.A. v. Capital Health Authority, 2004 CarswellAlta 926, [2004] Alta. L.R.B.R. 264, [2004] L.V.I. 3482-6, [2004] A.L.R.B.D. No. 38 Veilleux v. A.U.P.E., 2005 CarswellAlta 201, [2005] Alta. L.R.B.R. LD-10, [2005] A.W.L.D. 1388 HISTORICAL CONTEXT IN WHICH THE INSTANT “PARAMEDICAL” BARGAINING UNIT WAS FORMED “Looking Back, Looking Forward: A Legacy Report.” The Ontario Health Services Restructuring Commission (1996-2000). March, 2000. Doctors Hospital v. Ontario (Health Services Restructuring Commission) (1997), 3 Admin. L.R. (3d) 116, 73 A.C.W.S. (3d) 1001, [1997] O.J. No. 3704 (QL) (Ont. Div. Ct.). Toronto (City) [1998] OLRB Rep. September/October 772, [1998] O.L.R.D. No. 3769 (QL). North Bay General Hospital [2011] OLRB Rep. January/February 67, [2011] O.L.R.D. No. 621 (QL). REGULATORY COLLEGES AND HEALTH PROFESSIONS LEGISLATION RHPA Excerpts Medicine Act, 1991, SO 1991, c 30 Registration, O Reg 865/93, excerpts College of Optometrists of Ontario v. SHS Optical Ltd. (c.o.b. Great Glasses) (2003), 124 A.C.W.S. (3d) 1169, [2003] O.J. No. 3077 (QL) (Ont. S.C.J.). OLRB APPROACHES RE APPROPRIATE BARGAINING UNITS, Hospital for Sick Children [1985] OLRB Rep. Feb. 266. Metroland Printing, Publishing and Distributing Ltd. [2003] OLRB Rep. January/February 104, [2003] O.L.R.D. No. 514 (QL). Queensway General Hospital [1996] O.L.R.D. No. 44 (QL). Canadian Blood Services [2003] OLRB Rep. November/December 1014, [2003] O.L.R.D. No. 4295. NURSE PRACTITIONER CASES Credit Valley Hospital and Trillium Health Centre [2012] O.L.R.D. No. 4647 (QL). Northwestern Ontario Regional Cancer Centre and O.N.A. (2004), 135 L.A.C. (4th) 244, [2004] O.L.A.A. No. 969 (QL) (Keller, Ch.). Ottawa General Hospital v. O.N.A., 1984 CarswellOnt 1084, [1984] O.L.R.B. Rep. 1199. 140 EMPLOYER MATERIALS Physician and Clinical Assistants of Manitoba Inc v. Winnipeg Regional Health Authority [2014] M.L.B – 7057 (a Manitoba certification decision, without unfortunately any recitation of the facts or reasoning for the conclusion therein recorded) The Council of Academic Hospitals of Ontario v. Professional Association of Residents of Ontario (November 16, 2014) – an interest arbitration involving Residents The Professional Association of Interns and Residents of Ontario and Ontario Council of Administrators of Teaching Hospitals 1976 (Shime) – another interest arbitration involving Residents OPSEU v. Stratford General Hospital (1976) CarswellOnt 679 (Adams) [1976] OLRB Rep. Sept. 459